The Obama administration's reasons for charging banks $61 billion are disingenuous and transparently political. The tax has nothing to do with recouping Tarp costs or making the system safer.
Rather than wait for government or plaintiff lawyers to find them, banks that were involved in the syndication of mortgage backed securities should control their exposure through a proactive, rigorous self-study program.
The very first section of the very first topic in the CFPB's Supervision and Examination Manual goes right to the heart of the matter: the compliance obligations and potential liabilities of the board of directors.
So far, the bureau hasn't gone after many of the bad guys, even when their misdeeds are chronicled in the press and in civil court filings. Nor has it proposed, even informally, rules to curb known abuses.
If Citi, or any bank, turns the mobile channel into a scapegoat for its problems, it might leave a lasting impression that the channel is somehow unreliable.
"If we shower you with our largesse you will be required to sign away any future claims you may want to file against our valued partners in this agreement: the banks."
