Former CFPB Enforcers Launch New Consumer Protection Project

According to Reuters, three former senior enforcement lawyers from the U.S. Consumer Financial Protection Bureau are launching a “strategic enforcement project” to protect the public from corporate misconduct. Eric Halperin, Cara Petersen and Tara Mikkilineni – all former top CFPB enforcement attorneys – will lead the effort through the organization Protect Borrowers. The announcement came on Wednesday, November 12th, following President Donald Trump’s clampdown on the agency. The project aims to bring new litigation challenging products and practices that exploit workers, consumers and small business owners. This comes as the Trump administration has effectively neutralized the CFPB this year by idling its enforcement divisions and dropping enforcement actions.

Filling the enforcement vacuum

Here’s what’s really happening: The CFPB basically got gutted. The Trump administration claimed the agency was too political and should be abolished, so they’ve been systematically dismantling its enforcement capabilities. And when you take away the primary watchdog for consumer financial protection, guess what happens? Corporations get a free pass.

So these former enforcers aren’t just making a symbolic gesture – they’re creating an actual litigation machine to do what the government won’t. Halperin, who was the CFPB’s enforcement director, put it bluntly: “With no federal enforcement apparatus to ensure corporations are held accountable to the public, it’s only too easy for corporations to fleece consumers to line their pocketbooks.” That’s not just rhetoric – we’re talking about real people getting screwed while corporate profits soar.

Why this approach matters

Strategic enforcement isn’t about chasing every small violation. It’s about picking the right fights – the cases that set precedents, that change industry practices, that actually move the needle. These lawyers know exactly how the system works because they were inside it. They understand which legal arguments work, which corporate practices are most harmful, and how to build cases that stick.

Think about it: when you’ve got former top government lawyers who used to wield regulatory power now bringing private enforcement actions, that’s a pretty significant shift. They’re essentially creating a parallel enforcement structure using the court system instead of regulatory authority. It’s clever, really – using litigation as a substitute for regulation when the regulatory apparatus has been disabled.

The bigger picture

This isn’t happening in isolation. We’re seeing Democratic attorneys general and other consumer advocacy groups stepping up their enforcement efforts too. It’s like when the main fire department gets defunded – suddenly everyone starts forming volunteer fire brigades.

The timing couldn’t be more critical either. With economic pain indicators “flashing bright red” as Halperin noted, and corporate profits hitting record levels, the imbalance is stark. Workers and consumers are struggling while companies face less oversight than they have in years. This project represents one of the more organized attempts to rebalance that equation through the legal system.

What’s interesting is whether this becomes a sustainable model. Can private litigation effectively replace government enforcement? Probably not completely – but it might be the best option available right now. And with seasoned enforcers like these three leading the charge, corporations might find they can’t operate with quite the impunity they’ve been enjoying.