Yesterday, the Consumer Financial Protection Bureau (“CFPB”) filed suit against TransUnion, two of its subsidiaries, including TransUnion Interactive, Inc. (“TUI”), which markets and sells credit-related products such as credit scores, credit reports, and credit monitoring, and a longtime senior executive at TUI (the “Complaint”). The Complaint alleges that TransUnion, the two subsidiaries, and the senior executive violated a consent order the CFPB and the corporate defendants entered into in 2017 to resolve the CFPB’s findings that the corporate defendants engaged in deceptive acts and practices in the marketing and sale of credit products in violation of the Consumer Financial Protection Act of 2010 (“CFPA”) (the “2017 Consent Order”). The Complaint also alleges that the corporate defendants violated the Electronic Fund Transfer Act (“EFTA”) and its implementing regulation, Regulation E, and the Fair Credit Reporting Act (“FCRA”) and its implementing regulation, Regulation V. In our view, the Complaint is a significant development that should be considered by all persons subject to CFPB jurisdiction and, in particular, those subject to extant enforcement measures, as it demonstrates the CFPB’s intent to pursue a number of Director Chopra’s stated priorities: punishing corporate recidivism, holding executives accountable, and addressing alleged credit reporting agency misconduct.