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N.Y. Department of Financial Services Begins to Flex Dodd-Frank Muscles
25 April 2014
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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’s consumer financial protection provisions.
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