Consumer Financial Protection Bureau

What Would a CFPB Commission Have Done Differently?

02/14/17

Here’s the question CFPB commission proponents need to be able to answer convincingly:  what would the CFPB have done differently over the past five and a half years if it had been a commission, rather than a single director?  What supposed overreach would not have occurred?  

So, CFPB commission proponents, here's your chance. Comments are open.

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More Evidence that a For-Cause Removal of CFPB Director Corday Would Be Pretextual

02/03/17

If Trump is planning on attempting to remove CFPB Director Richard Cordray "for cause" he's hardly going about it in a smart way.  The Trump administration keeps generating more and more evidence that any for-cause removal would be purely pretextual, which strengthens Corday's hand were he to litigate the removal order (as he surely would).  

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The Real Reason Behind the Calls for Firing Richard Corday (and the Costs of Doing So)

01/05/17

The calls for Donald Trump to fire CFPB Director Richard Cordray are getting louder (see here and here). It's worthwhile understanding what's really afoot here. Cordray's term as CFPB Director expires in July 2018, so firing him in January 2017 doesn't seem to accomplish a lot.

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CFPB Commission Structure Proposals

12/29/16

I have an op-ed in American Banker about proposals to convert the CFPB into a commission structure.  Basically, the idea that a commission structure increases accountability and policy stability and reduces arbitrary or abusive actions by an agency just doesn't hold water upon examination.  

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CFPB Tales Told Out of School

12/21/16

Former CFPB enforcement attorney Ronald Rubin has a lengthy attack on the CFPB in the National Review. It's got lots of sultry details, but there's nothing new and verifiable in the piece.

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Fake News, Special Carrie Sheffield CFPB Edition

12/19/16

The "fake news" phenomenon has gotten a lot of attention of late, but there's also the problem of its kissing cousins, faux academic research and opinions piece that springboards off of fake news and faux research.  A comically bad example of the latter category is the hatchet job Carrie Sheffield tries to pull on the CFPB in a piece on Salon.com.

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CFPB and ACICS Retrospective

12/16/16

The Department of Education just stripped the Accrediting Council for Independent Colleges and Schools of its accreditation role.  (For those of you not in academy, this accreditation is critical for schools to get DoE funds, among other things.  It's part of what enables the ABA's on-going tyranny of legal education.)  Some of you might remember that in 2015, the CFPB issued a Civil Investigative Demand to ACICS, the authority for which ACICS challenged successfully.

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How Consumers Use the CFPB's Complaint Function

12/12/16

I recently posted to SSRN my new article, Calling on the CFPB for Help: Telling Stories and Consumer Protection (Law & Contemporary Problems, forthcoming 2017).

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The CFPB and Behavioral Economics

11/28/16
This post is an extended aside from my previous post about David Evans' argument about the CFPB's mindset and institutional incentives.  The point isn't critical to Evans' argument, but I'm writing because it really irks me because it shows such a lack of understanding about the CFPB.
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The CFPB and Consumer Welfare

11/28/16
David Evans has an interesting article on PYMNTS that argues that "The fundamental problem with the CFPB ... isn’t who’s on top.
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