Regulatory

CFPB and PFOF: Why the Consumer Finance Regulator Is Silent

The CFPB mandate to prevent unfair, deceptive, or abusive financial practices should cover PFOF conflicts — yet the agency has been silent.

UDAAP Case

PFOF creates undisclosed conflicts and inferior execution — classic unfair or deceptive acts and practices under CFPB jurisdiction.

Jurisdiction Overlap

SEC primary jurisdiction over broker-dealers and CFPB consumer mandate overlap on PFOF — creating a gap both agencies exploit to avoid acting.

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