Nobody has ever made a strong case that the pre-Dodd-Frank framework failed, much less that a new federal agency was necessary to protect consumers. CFPB advocates act as though there would be no consumer protection in financial markets without this government agency, but that’s demonstrably false.
Dodd-Frank transferred enforcement of 22 specific consumer financial protection statutes from other agencies to the CFPB.
Prior to Dodd-Frank, federal rulemaking and enforcement for consumer financial protection laws were divided among seven agencies: the Federal Reserve Board of Governors; the Federal Deposit Insurance Corporation; the Office of the Comptroller of the Currency; the Office of Thrift Supervision; the National Credit Union Administration; the Federal Trade Commission, and the Department of Housing and Urban Development.
States also had – and still have – their own consumer protection laws. And, the Department of Justice generally enforces anti-discrimination law when financial institutions are alleged to have perpetrated such crimes.
https://www.forbes.com/sites/norbertmichel/2017/01/24/the-cfpb-is-in-the-crosshairs-exactly-where-it-belongs/#3c3de7001a4f