N.Y. Department of Financial Services Begins to Flex Dodd-Frank Muscles

25 April 2014
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Key takeaways:

  • By bringing consumer financial enforcement actions under Section 1042 of the Dodd-Frank Act, state officials may enjoy access to better discovery tools and potentially could obtain higher penalties.
  • Increased state use of Section 1042 may spark increased concurrent and follow-on federal enforcement activity.
  • A proliferation of state enforcement actions could lead, in the near term, to conflicting judicial interpretations of Dodd-Frank‚Äôs consumer financial protection provisions.