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Financial Services Law Insights and Observations

CFPB releases ethics guidance

Federal Issues CFPB Consumer Finance

Federal Issues

On November 19, the CFPB released a blog post providing guidance regarding revolving door misconduct and reminding Bureau staff to report suspicious communications and activity committed by former employees to agency officials. According to CFPB Director Rohit Chopra, the reminder will permit the Bureau to detect activity by former employees and other government agencies who may be in violation of existing ethics and confidential information disclosure laws and regulations. Chopra noted that parties using services of a former Bureau employee will be subject to “heightened scrutiny to matters and decisions where a party has employed or retained the services of a former employee to ensure that the CFPB is meeting the highest standards of ethics and integrity implemented nearly a decade ago." Among other things, the guidance disclosed areas to foster the CFPB’s standard of exemplary integrity, safeguard confidential information, and protect the Bureau’s decision-making process through: (i) protecting supervisory, confidential, and non-public CFPB information; (ii) reporting potentially unlawful communications by former federal employees; and (iii) reporting any communications with the Bureau during a former employee's first year.