The Consumer Financial Protection Bureau Dismantled: What Does It Mean, and What Comes Next?

Keith Bradley
Steve Conigliaro
David L. Coats
Keith Bradley | Squire Patton Boggs
Steve Conigliaro | Squire Patton Boggs
David L. Coats | Squire Patton Boggs
Live Video-Broadcast: March 26, 2025

2 hour CLE

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Program Summary

The Trump Administration has taken a sledgehammer to the Consumer Financial Protection Bureau –closing its headquarters, firing staff, refusing to draw down funding, and ordering a halt to activities. We will explain what these steps actually mean for the implementation of federal consumer financial law, by exploring what the Bureau's authorities are, how it functions, and what other actors might step in if the Bureau ceases to function.

Key topics to be discussed:

  • Basics of the Consumer Financial Protection Act (and Dodd-Frank Act Title XIV)
  • Past Constitutional Controversies
  • What Does the CFPB Actually Do?
  • Recent CFPB Rulemakings
  • Alternative Enforcement Possibilities for CFPB Laws
  • The Bureau and the Mortgage Markets

Date / Time: March 26, 2025

  • 1:00 pm – 3:10 pm Eastern
  • 12:00 pm – 2:10 pm Central
  • 11:00 am – 1:10 pm Mountain
  • 10:00 am – 12:10 pm Pacific

Closed-captioning available

Speakers

Speaker_Keith Bradley_myLawCLEKeith Bradley | Squire Patton Boggs

Keith Bradley is co-chair of the Appellate & Supreme Court Practice. He represents companies and individuals in appeals before federal and state courts and has argued before appeals courts across around the country. He specializes in challenges to regulatory policy, such as Administrative Procedure Act litigation. He has achieved substantial results in litigation across a spectrum of agencies, including the Environmental Protection Agency (EPA), Health and Human Services (HHS), Department of Energy (DOE) and more.

Keith also counsels clients on regulatory compliance and represents them before US federal and state agencies across multiple regulatory regimes, especially in the financial and energy sectors. He works with multiple companies in the securities industry, in renewable energy, in consumer finance, and others. As a senior advisor to the General Counsel of the U.S. Department of Energy (DOE), Keith organized the defense of significant regulatory challenges and advised on important department regulatory reforms, such as those in energy conservation and nuclear export controls. He advised on complex DOE transactions, such as decommissioning contracts funded in part by barter arrangements, federal participation in transmission line projects, and more.

Before joining DOE, he was counsel in the Legal Division of the Consumer Financial Protection Bureau, where he helped draft significant regulations, counseled senior agency executives on administrative and constitutional law, and worked with enforcement teams on some of the bureau’s most significant matters. He has also been in-house counsel in the financial sector, building and running the compliance management system for the first nationwide mortgage brokerage franchise.

Keith is a member of the American Law Institute, and teaches administrative law at the University of Denver Sturm College of Law.

Keith is also a physicist who developed nanoelectronic sensor systems at a technology startup. He has 13 issued patents to his name.

keith.bradley@squirepb.com | T +1 303 894 6156

 

Spekaer_Steve Conigliaro_myLawCLESteve Conigliaro | Squire Patton Boggs

Steve Conigliaro is a principal in the firm’s Financial Services Practice and provides strategic counsel to clients on a wide range of consumer banking and bank regulatory matters. During Steve’s 20+ year legal, risk and compliance career in financial services, he has been a trusted advisor to the world’s largest national banks, foreign banking organizations, credit unions, auto captive finance companies, payment card networks, mortgage originators, student lending servicers and payment card issuing and acquiring banks.

Steve served in leadership roles in several corporate compliance and legal departments, including with some of the largest national banks in the US. He has distinguished himself with deep regulatory knowledge and expertise and has been working at the forefront of consumer banking regulation since the creation of Dodd Frank in 2010. Steve has advocated on behalf of his clients on supervisory and enforcement matters with the Office of the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Consumer Financial Protection Bureau.

Steve counsels clients on all legal, regulatory and compliance requirements for retail and branch banking, digital banking, payments, mortgage originations and servicing, auto finance, credit cards, unsecured personal lending and buy-now-pay-later and student lending. He has led many important strategic transactions and partnership negotiations including auto finance-OEM private label agreements, whole loan purchase agreements with major point-of-sale personal loan originators and mortgage originators, mortgage loan servicing rights agreements and transformational bank partnership agreements with financial services technology providers. Steve also has a strong track record of successfully defending financial institutions on alleged fair lending violations under ECOA, FHA and CRA and has resolved matters in supervision and in enforcement for auto finance, mortgage and branch banking clients.

Steve began his legal career at a leading global law firm and was a founding member of its Financial Services Practice Group, where he specialized in representing payment card networks, banks and other financial institutions in compliance, litigation and regulatory enforcement actions.

steven.conigliaro@squirepb.com | T +1 602 528 4009

 

Speaker_David L. Coats_myLawCLEDavid L. Coats | Squire Patton Boggs

David is a commercial litigator with a focus on consumer protection, consumer finance, and privacy law. He helps businesses with their litigation needs and defends them when facing enforcement actions. In addition to his commercial litigation practice, David advises businesses on how to comply with the labyrinthine state and federal laws governing consumer finance, licensing and privacy laws. A former Colorado Assistant Attorney General and Denver Deputy District Attorney, David has litigated more than 20 trials. Today, David uses his prosecution and compliance experience to help clients put their best foot forward.

Prior to becoming an attorney, David worked for a global non-profit in Moscow, Russia that taught college students how to become social entrepreneurs. His pro bono work focuses on assisting non-profits and inmates. While in law school, he clerked for judges at the Colorado Supreme Court and the US District Court for the District of Colorado. He also worked at the Colorado Attorney General’s Office and the US Attorney’s Office. David was a Chancellor’s Scholar at the University of Denver and a clerk at the Colorado Court of Appeals. He is an avid mountaineer and a local leader for the Boy Scouts of America.

david.coats@squirepb.com | T +1 303 894 6105

Agenda

I. Basics of the Consumer Financial Protection Act (and Dodd-Frank Act Title XIV) | 1:00pm – 1:20pm

II. Past Constitutional Controversies | 1:20pm – 1:40pm

III. What Does the CFPB Actually Do? | 1:40pm – 2:00pm

Break | 2:00pm – 2:10pm

IV. Recent CFPB Rulemakings | 2:10pm – 2:30pm

V. Alternative Enforcement Possibilities for CFPB Laws | 2:30pm – 2:50pm

VI. The Bureau and the Mortgage Markets | 2:50pm – 3:10pm

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for CLE Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hours

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2.5 General

Receive CLE credit in Florida via attorney submission.
Georgia

Pending CLE Approval
2 General

Hawaii

Approved for CLE Credits
2.4 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for CLE Credits
2 General

Indiana

Approved for CLE Credits
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hours

Maryland

No MCLE Required
2 CLE Hours

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hours

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for CLE Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General Minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for CLE Credits
2 General

Nevada

Approved for CLE Credits
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Pending CLE Approval
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for CLE Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hours

Tennessee

Approved for CLE Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal

Receive CLE credit in Washington via attorney submission.
Wisconsin

Pending CLE Approval
2.4 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Pending CLE Approval
2 General

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