In 2017, 17 state attorneys general pledged to step in and fill the gap if the CFPB becomes less aggressive under acting Director Mick Mulvaney.

Only a few states announced plans to create 'mini-CFPBs' that would focus on consumer issues in their respective jurisdictions. In most states, budgets have been too constrained for AGs to expand beyond what they were already doing to assist the CFPB.

Ballard Spahr Partner Christopher Willis said, "All the states were already at capacity in terms of their ability to ramp up their enforcement activity. The states are doing as much as they can with constrained budgets and staff, and those constraints have not changed."

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