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Our Mission
The increasing role of State Attorneys General in law enforcement with respect to financial services providers is one of the most significant developments impacting the financial services industry in recent years. The financial crisis has focused the attention of State Attorneys General on the protection of consumers in their states and has led to a number of high profile investigations being initiated, the most recent of which involves foreclosure practices of mortgage loan servicers. In addition, the recently enacted Dodd-Frank Act contains a number of important provisions designed to further enhance the ability of State Attorneys General to investigate and pursue remedies for acts or practices by financial services companies that they believe have an adverse impact on citizens of their states without the historic federal preemption limitations.

The regulatory environment for the financial services industry has never been more challenging. Traditional Federal regulatory authorities have been supplemented with a new entity - the Consumer Financial Protection Bureau (CFPB) - whose scope of authority and day-to-day impacts upon the industry remain largely undefined. The CFPB has made clear that it intends to coordinate its own actions with those of state-level regulators and other officials, particularly the State Attorneys General. "The CFPB Director, former Ohio Attorney General Richard Cordray, has stated that the Bureau" will depend on the expertise and experience of State Attorneys General as we work together to protect consumers."

To navigate the anticipated increased Federal-State oversight of the industry's activities, STAGE Network proactively monitors, analyzes and reports on (1) State Attorneys General policy and enforcement initiatives; (2) State-level legislative and regulatory initiatives that apply to banks and their subsidiaries as a result of changes in preemption standards; and (3) distribution of enforcement responsibilities among the Bureau of Consumer Financial Protection (CFPB), the State Attorneys Generals, and other state enforcers/regulators.

Our Services
Specific STAGE Network activities include:
  • in-person meetings and web conferences providing an opportunity for counsel to financial services companies to share insights among themselves
  • reports to members summarizing AG and state agency initiatives that impact the financial services industry
  • monitoring and assessing of federal preemption issues relevant to financial services providers
  • liaison with State AGs at their meetings and individually as necessary
  • coordinated industry legal response to AG initiatives as judged appropriate through:
    • jointly developed model legal briefs to respond to legal actions that potentially have industry-wide implications
    • amicus briefs in support of industry positions
    • other coordinated legal, regulatory, or legislative initiatives that are determined to be appropriate.




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