CPFB officials have announced that their enforcement system will be “based largely on the existing, stable model” used by the Federal Trade Commission. While this sheds some light on the framework of the CFPB’s new system, it does not go into detail about the role that supervision will play in the agency’s enforcement plans. The only other indication of how the agency will handle this process comes from the CFPB’s website:

Peggy Twohig, the bureau’s assistant director for non-bank supervision, and Steve Antonakes, the assistant director for large-bank supervision, hinted in a July 22 blog post that the agency may rely heavily on supervision.

“Generally as a last resort, examiners will coordinate and work closely with CFPB’s enforcement staff to implement appropriate enforcement actions to address violations of law that harm consumers,” Twohig and Antonakes wrote.