This is the memorandum of law our attorneys filed with the U.S. District Court in support of our successful motion for summary judgment in our lawsuit against the Trump CFPB for establishing an illegal “TaskForce on Federal Consumer Financial Law.” It is downloadable from this page. Brief excerpt:
Congress established the Consumer Financial Protection Bureau to protect consumers from confusing, predatory financial products in the aftermath of the 2008 financial crisis. Twelve years later, the Bureau chartered a Taskforce on Federal Consumer Financial Law, purportedly to examine consumer finance laws and report its recommendations for how to improve them. The Federal Advisory Committee Act, or FACA, was designed to ensure that committees like the Taskforce serve the public interest. Yet the Bureau created the Taskforce without even attempting to comply with FACA’s most basic requirements—the Bureau never showed any need for the Taskforce, the Taskforce largely conducted its operations in secret, and the Taskforce was composed of a biased slate of individuals with ties to the consumer finance industry that the Bureau was established to regulate.[…]
For these reasons, the Court should grant summary judgment to Plaintiffs and order all relief necessary to remedy Plaintiffs’ harms and uphold FACA’s purposes, including a use injunction, a limited use injunction (in the form of a disclaimer on the Report’s cover), the release of all remaining Taskforce records, and a declaratory judgment.