Regulatory: Title X’s designated transfer date

The transfer date is here; now what?

This column is part a series of articles on the new Consumer Financial Protection Bureau and the upcoming wave of regulations affecting the consumer financial industry.

On July 21, 2011—the “designated transfer date” in the parlance of Title X of the Dodd-Frank Act—the new Consumer Financial Protection Bureau will officially open its doors and inherit the remainder of its many and considerable powers. With the designated transfer date looming on the horizon, now is a good time to take a look at the significance of the date in the broader context of the Act and the upcoming regulatory onslaught.

Within two years of the designated transfer date:

  • Through the bureau’s Office of Financial Education, the Director is required to submit its first annual report on its (1) financial literacy activities, and (2) strategy to improve consumer financial literacy. The annual report goes to the Senate’s Committee on Banking, Housing and Urban Affairs, and the House’s Committee on Financial Services.
  • The bureau is tasked with monitoring the risks presented to consumers by consumer financial products and services. Beginning two years after the designated transfer date, the bureau must publish at least one report per year detailing the “significant findings” of its monitoring activities.
  • The protection from pay decreases, involuntary separation, and involuntary reassignment afforded employees transferred from transferor employees expires.

Within three years of the designated transfer date:

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Martin Bishop

Martin J. Bishop is a partner, litigation department vice chairman and co-chair of the consumer financial services litigation practice at Foley & Lardner LLP. He...

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