Thoughts & Comments
The CFPB Is Going To Be A Disaster
An virtually unlimited budget combined with zero accountability is a toxic combination

Thomas Brown  ( about me )
Posted 05/10/2012
bankstocks.com
tbrown@bankstocks.com

Writing in Bank Director, Jack Milligan appears to have lost his mind:

The [CFPB] is the subject of this issue’s cover story, and as I worked on it I kept asking myself whether the country really needs another regulatory agency.  I have made my own calculation and decided the answer is yes. And no. [Emph. added] 

As it happens, Milligan is one of the most thoughtful and knowledgeable banking writers around, but if he thinks—if anyone thinks—that the Consumer Financial Protection Bureau is going to turn out to be anything other than an unmitigated disaster for the banking industry, he’s kidding himself.

Fact: Funding of the CFPB is not subject to Congressional oversight. The agency essentially names its own budget and is financed directly from the profits of the Federal Reserve.

Fact: The CFPB is not run, as other regulators such as the SEC are, by a bipartisan board of commissioners, but rather by a single, un-fireable individual appointed to a five-year term.  

Fact: The CFPB is nominally housed inside the Federal Reserve, but its director merely has to “consult” with other regulators (or the Secretary of the Treasury, for that matter), rather than take orders from them. He can do whatever he wants.

Fact: The CFPB has unlimited authority to gather data and information from the institutions it oversees; its power is so broad it even has a mandate to monitor their diversity practices. 

In all, the CFPB has a vast reach and is accountable to no one. As we have said before, this is a recipe for catastrophe. In his cover story, Milligan tries to argue that we won’t really know how destructive the CFPB will be for five years, once the agency has developed a record of enforcement. Baloney. Besides, it’s too dangerous to wait that long to find out. The agency could wreak regulatory havoc over that time. There are already a plethora of federal bureaucracies to protect consumers from abusive practices. We need better enforcement, not more watchdogs—and certainly not watchdogs that are unaccountable. As it is, banks are already regulated by  the OCC, the Fed, the FDIC, the FTC, the Justice Department, the CFTC, state banking regulators, and state attorneys general. Another new bureaucracy is going to help?

Jack also seems to have been seduced by the conventional wisdom that says that the credit crunch came about as a result of the development of certain inherently dangerous lending products such as pick-a-pay and alt-A mortgages. No. As a new study by the Atlanta and Boston Feds makes plain, that conventional wisdom is flat wrong. It wasn’t any newfangled products that caused the problems (most have been around for decades, anyway), it was lax underwriting that did it. There were already plenty of regulators around that could have stopped the craziness—and they didn’t. Next time around, the CFPB (which doesn’t even concern itself with safety and soundness, remember) won’t be likely to either.  

I am still in shock that Bank Director, of all magazines, wouldn’t see the CFPB for the monstrosity that it is. No other government agency has as much unaccountable power. We need streamlined effective regulation, not one more, even-more-powerful regulatory agency. Bank Director should be advocating for its reform or outright elimination. After all the years we’ve known each other, don’t go soft on me now, Jack!

What do you think? Let me know!


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Former First Marblehead investor Posted On 5/10/2012 12:58:38 PM

This is utter nonsense. With less regulation we got the 2007-08 disaster, a gift brom BAC, C, etc. etc. Shame on you.

Former First Marblehead investor Posted On 5/10/2012 12:59:55 PM

B.S. We need someone to ride herd over BAC, C, and all the other crooks who brought us disaster in 2007-08.

John Lauroesch Posted On 5/10/2012 1:01:56 PM

Every time you write something like this serves to show you are out of touch with what really has been happening in the consumer as a result of bank greed. If banks were run by reasonable people perhaps there would be no need for the CFPB. However they have shown themselves to be willing to takew tremendous risk and abuse their customers if left unchecked. Great real.

Michael Lewis Fan Posted On 5/10/2012 1:27:31 PM

The Hydra headed behemoth that led to the great housing finance bubble, was just that, a perfect storm coming together from many variables. There are no single solutions. Which ever system we construct will have a risk profile Example: think S&L Industry... borrow short/lend long at fixed rate. Terrific until you get sustained inflation. Securitization: Terrific until you start throwing low grade garbage in with decent paper. And the list goes on. Extension of credit is by definition an extension of the social contract. Our "social contract" includes strong support for housing ownership. So, no surprise that the train goes off the track there with some frequency. What else. Yes, regulation should be as straightforward as possible. Good luck. Undecided but

rivvir Posted On 5/10/2012 1:28:25 PM

Whatever happened to the days when banks were banks, or, what was it, savings and loans?, made a lot of money, were satisfied with those returns, didn't hand out billions, with a b, to their senior managements, and almost never got into financial problems that threatened their survival. All without resorting to egregious fees, where fees were part of their income, and acting within the confines of regulation. I'm not even asking for a return to the days of 5% savings accounts, i realize the low rates put in by the fed, on which banks clear about 2 1/2% or so by the way without having to lift a finger, no? Why aren't you looking into what it will take to get us back a financial system that worked pretty well for the consumer, and business, not against him and it solely for the sake of itself and its ceo's bonus? You want to clear up the banking system? And probably most other lines of work. Get rid of bonuses, make sure the ceo gets a good salary, and fire his ass immediately if he doesn't do the job he was hired to do.

jsc173 Posted On 5/10/2012 2:17:16 PM

Here's the problem with CFPB. The hope was that they would populate the bureau with skilled, knowledgeable bankers and technical staff who would bring a different mindset to the challenge they have. There was the opportunity this organization could be more proactive than the alphabet soup of OCC, OTS and FDIC was ever able to do. Last I heard, most of the folks in the upper echelons of CFPB are retreads from some other government regulatory agency. So it appears they've solved nothing other than, for the larger banks, there will be another examination process. It's a great prescription for yet more interference with the process, an additional increase in the cost needed to run a bank (for those who aren't bankers, an exam for even a small bank can last 2-3 months with a handful of your staff monopolized by the examiners) and the risk that these new examiners will ignore everything the other examiners did six months before. A joke. A nightmare. A prescription for yet another disaster a few years down the road.

rivvir Posted On 5/10/2012 6:39:41 PM

I am surprised no one posted on this yet. Well, here it is: http://dealbook.nytimes.com/2012/05/10/jpmorgan-discloses-significant-losses-in-trading-group/?partner=yahoofinance "...big bets the JPMorgan unit was reportedly making in credit default swaps." "Now, the portfolio is wreaking havoc at the bank. In its filing on Thursday, JPMorgan pointed specifically to problems with its bets on credit." "One new regulation, the Volcker Rule, aims to stop banks from making bets with their own money. Mr. Dimon has been an especially forceful critic of the rule, saying it goes too far." "The JPMorgan problems surfaced in a group that makes proprietary trades. But the unit is supposed to hedge against losses in other parts of the bank, which means it might not run afoul of the Volcker Rule once it is put into effect. Even so, Mr. Dimon acknowledged the trading losses could add to the debate about financial regulation. “It’s very unfortunate,” he said. “It plays right into the hands of a bunch of pundits out there, but that’s life.” “This may not have violated the Volcker Rule, but it violates the Dimon Principle.”" I appreciate the candor, though he did play it down in april. What i don't appreciate is the fact that these plays can significantly damage a bank, even though designed to hedge. We really don't want to be forced to bail anybody out anymore. You can win 1000 times in a row, but 1001 can be big enough of a loss to put you out of business. Permanently. Just like jaywalking while you're texting. See the 3 deaths in fort lee?

JRG Posted On 5/11/2012 9:21:25 AM

Why would you think that our completely dysfunctional congress could any provide any meaningful ovesight of this agency other than to water down or block any appropriate impact the agency might have. The financial services industry is the most powerful lobby in Washington and would have tremendous influnece on the members of the oversight committee. Maybe this is what you are objecting to.

wallstreetcritic Posted On 5/11/2012 11:04:20 AM

Tom, I am a day late writing this because I was busy yesterday trying to make a living. It is timely today however, given the revelations about J.P. Morgan and their loss. I guess they will try and make it up by raising fees somewhere on the average consumer. Thats why we need the CFPB

Community Banker 35 Posted On 5/11/2012 11:56:08 AM

All of these so called experts and financial geniuses trying to create or reegineer regulations/regulators to prevent another occcurance of the problem. How about a short one liner (not 2,000 pages) reg like "you shall not lend more than 80% of the value of the collateral and you shall document and verify the borrower's ability and capacity to repay." Seems like that would be fairly easy to regulate and enforece. Here is quote from one of our President's advisors, Warren Buffett, "If homebuyers throughout the country had behaved like our buyers (Clayton Homes), America would not have had the crisis that it did. Our approach was simply to get a meaningful down payment and gear fixed monthly payments to a sensible percentage of income. This policy kept Clayton solvent and also kept buyers in their homes… A house can be a nightmare if the buyer's eyes are bigger than his wallet and if a lender – often protected by a government guarantee – facilitates his fantasy. Our country's social goal should not be to put families into the house of their dreams, but rather to put them into a house they can afford." Enough said.

rivvir Posted On 5/11/2012 1:05:51 PM

Community, that's cool, and a good guide. Unfortunately you restrict it to homes. Yeah, this past crisis was homes, and homes are a big chunk, but not the only way for banks to get into trouble. If one size fit all then i'd go with you. One size doesn't. That's why what's needed is more than one line. You can be sure the banks will, if restricted in one sector, look to play their little game in others. Further unfortunately, 2000 pages may be needed to cover all the contingencies which banks may use to get around the regs put over them. You can bet 2000 pages won't be enough. There'll always be some route found no one ever thought of before. We are Americans, we are probably the most innovative people in the world. Some day we are gonna innovate ourselves right out of business. Nearly did it several years ago, didn't we. One day we shall succeed.

Community Banker 35 Posted On 5/11/2012 1:41:40 PM

rivvir: First, I didn't limit my proposed reg to homes (Buffett did). Its simply banking/lending 101. Look, you can't simply cannot legislate human behavior...we have over 70,000 pages of IRS rules and regs that force many citizens to use tax lawyers and accountants to find loophopes...and it doesn't stop people from cheating on paying their taxes. I have been a community banker for over 35 years and have witnessed the evolution of consumer protection laws. In my opinin, they like a vast other number laws and regs are well intentioned but many woefully ineffective. Many of these regs require consumer disclosures designed for the stated purpose of having an informed consumer. Well thousands of pages of consumer protection regs later, it didn't stop people or wall st or the govt from foolish behavior. It just seems to me the beneficiaries of all this undue paper are attorneys, acccountants and politicans. It has certainly (trust me) driven up the cost to the consumer (hmmm....almost seems like a hidden tax that politicans don't want to talk about) . If you really want to protect the financial system from catastropic foolish behavior, break up the big banks and never again privatize profits and socialize losses (crony capitalism?).

Susie Flint Posted On 5/11/2012 1:50:11 PM

I am new to lending but have 20 year within the industry. Life is hard but this doesn't have to be this hard, it all comes back to just be HUMAN - honest and stop trying to take the next person for a ride down a path that isn't the best for them. Stop with another regulation and offer a program that people can DO and UNDERSTAND. The first bank that takes that step will have all the loyal customers and they won't have to promise anything because it will show they care about their customers and people will word of mouth them untold profits.

Community Banker 35 Posted On 5/11/2012 2:36:33 PM

Susie Flint: In a perfect world, I 100% agree with you...but even with a mountain of laws, prisons, and punishment, murder and robbery still occur everyday (some humans being unhuman...which unfortunately is a frequent occurence). My point is( to stay on the CFPB topic) in spite of all of these new laws/regs/bureaus/czars, (which all sound good on paper) will not, has not ever stopped crap, financial or otherwise, from happening! For my 60 year life, governments create new laws and regs each and every year to manage every aspect of societal existence. For 1 year in my life I would like to see more laws repealed that passed (likely chance, since politicians wouldn't have anything to get re-elected on).

Community Banker 35 Posted On 5/11/2012 2:46:36 PM

Susie Flint: In a perfect world, I 100% agree with you...but even with a mountain of laws, prisons, and punishment, murder and robbery still occur everyday (some humans being unhuman...which unfortunately is a frequent occurence). My point is( to stay on the CFPB topic) in spite of all of these new laws/regs/bureaus/czars, (which all sound good on paper) will not, has not ever stopped crap, financial or otherwise, from happening! For my 60 year life, governments create new laws and regs each and every year to manage every aspect of societal existence. For 1 year in my life I would like to see more laws repealed that passed (likely chance, since politicians wouldn't have anything to get re-elected on).

Community Banker 35 Posted On 5/11/2012 3:06:19 PM

Susie Flint: In a perfect world, I 100% agree with you...but even with a mountain of laws, prisons, and punishment, murder and robbery still occur everyday (some humans being unhuman...which unfortunately is a frequent occurence). My point is( to stay on the CFPB topic) in spite of all of these new laws/regs/bureaus/czars, (which all sound good on paper) will not, has not ever stopped crap, financial or otherwise, from happening! For my 60 year life, governments create new laws and regs each and every year to manage every aspect of societal existence. For 1 year in my life I would like to see more laws repealed that passed (likely chance, since politicians wouldn't have anything to get re-elected on).

Randy B. Posted On 5/11/2012 4:15:17 PM

Cherokee Liz is still beating the war drums. Cordray is just a front.

rivvir Posted On 5/11/2012 5:42:38 PM

"we have over 70,000 pages of IRS rules and regs that force many citizens to use tax lawyers and accountants to find loophopes" Kind of negates your whole premise, doesn't it? Nobody, and nothing, forces anyone to find loopholes. Citizens, and businesses, do it to get around the rules and regs. Since that's the case the book gets ever larger in an attempt to not create loopholes in the first place and to close them once they are discovered.

Community Banker 35 Posted On 5/11/2012 6:33:11 PM

Yea, and all these unnecessary laws and regs kind of negates the concept of freedom and liberty. Its interesting that money magazine used to run an article each year during income tax season. They submitted identical tax return info to several accountants and the IRS to determine the computed tax liability. Guess what, each tax preparer had calculated a different tax liability (this experiment was repeated several years with the same outcome each year). Moral of the story (beyond tax fairness issues) is how a compounding volume of laws and regs create unintended consquences that is beyond politicans abiltiy to foresee. Try to solve one problem...create another which we now need a new law to fix. Seems to me like a dog chasing its tail.

Community Banker 35 Posted On 5/11/2012 6:39:46 PM

Yea, and all these unnecessary laws and regs kind of negates the concept of freedom and liberty. Its interesting that money magazine used to run an article each year during income tax season. They submitted identical tax return info to several accountants and the IRS to determine the computed tax liability. Guess what, each tax preparer had calculated a different tax liability (this experiment was repeated several years with the same outcome each year). Moral of the story (beyond tax fairness issues) is how a compounding volume of laws and regs create unintended consquences that is beyond politicans abiltiy to foresee. Try to solve one problem...create another which we now need a new law to fix. Seems to me like a dog chasing its tail.

rivvir Posted On 5/11/2012 6:41:42 PM

"... all these unnecessary laws and regs kind of negates the concept of freedom and liberty." Yah think? I guess then we should do away with the 10 commandments. Or is it only the laws and regs you personally find to be unnecessary that negate the concept of freedom and liberty? Me, i'd rather be free of having to bail you guys out again. That'd give me the liberty to walk the streets without the worry of you ruining my financial system on my mind. All kinds of freedoms and liberties, aren't there.

Community Banker 35 Posted On 5/11/2012 6:59:50 PM

I'm disappointed you have elected to sterotype me and my bank. For starters, my bank has never received any federal aid (TARP) or SBLF funds. We have been in business over 100 years having lent millions of dollars to small businesses (that has resulted in thousand of jobs being created) and individuals. Save your irresponsible comments for the wall st. guys, they deserve it.

rivvir Posted On 5/11/2012 7:10:44 PM

Not you and your bank. Your industry. This society relies on your industry, not just your bank. Stop your irresponsible twisting in the wind.

jane doe Posted On 5/14/2012 3:06:39 PM

Nonsense is right. Mr Brown would like to have no regulations at all . Just like Mr Dimon blasted the new regulations after the last the mess all the banks caused . If Mr Dimon is one of the best CEOs in the banking sector i cant even imagine how in competant the rest of them are !!!!!! Most working people when the dont preform there jobs well get fired. Shame on all of you for your greed

jane doe Posted On 5/14/2012 3:10:57 PM

Nonsense is right. Mr Brown would like to have no regulations at all . Just like Mr Dimon blasted the new regulations after the last the mess all the banks caused . If Mr Dimon is one of the best CEOs in the banking sector i cant even imagine how in competant the rest of them are !!!!!! Most working people when the dont preform there jobs well get fired. Shame on all of you for your greed

jane doe Posted On 5/14/2012 3:17:23 PM

All the CEOs should learn what it means to have Integrity then , THey would not have to be so regulated

FrankRauscher Posted On 5/18/2012 10:29:00 AM

FACT: CONSUMERS HAVE BEEN ABUSED BY IRRESPONSIBLE LENDING PRACTICES FACT: BANKS ARE NOT TRUSTED OR RESPECTED ANYMORE There is no industry self-regulation. I will just focus a little on consumer credit. Everyone knows about the consequences of incompetence in mortgage lending. Starting with Citibank’s mass issue of credit cards in the 1970’s to a public that had not requested them. It was followed by massive wave of bankruptcies, and then Congress reacted by requiring customers to apply for credit. And Citibank lobbied to get the bankruptcy laws tightened. Then Citibank lobbied South Dakota in the 1980’s to eliminate interest rate caps (which every State had in place for years) so they could increase and export rates around the US and add additional portfolio risk and suck additional consumers into a credit death spiral followed by more bankruptcies. Interest rates slowly broached 30% and banks responded by reducing the minimum monthly payments to permanently entrap the lower middle income class into another credit death spiral. Other credit card companies did the same. Additional card only companies launched “fee harvesting” credit programs that regulators could not rein in because regulators act after the fact if and when the loan losses appear. Smart card company owners sold out to bigger banks where it took time for losses to become offset by reduced operating expenses. In the race for consolidation of credit cards, large goodwill premiums were paid which required a continued surge of weaker underwriting (remember the stories of all the people with $100,000+ in aggregate credit card lines) and excessive fees to achieve higher returns. Enhanced lifestyles were being financed with credit cards and the cards were being repaid by extracting home equity via home flipping or home equity credit. It only works when home values increase quickly. We know what happened. When approached by consumer advocates including me, the 8 largest card issuers would individ

FrankRauscher Posted On 5/18/2012 10:35:10 AM

continued: When approached by consumer advocates including me, the 8 largest card issuers would individually acknowledge the abusive situation but were afraid to go first because of fear that no one would follow and the equity analysts would challenge their “competence” for not achieving peer returns. Even after Dodd-Frank and the Durbin Amendment and the Card Act, we can see the cycle happening again with the bank version of payday lending led by Wells Fargo, US Bank, and Regions Bank. Interest rates are 90%-300% PERVERSE ADVANTAGE- Exporting 90% - 300% - interest rates, etc. especially to states that have outlawed or placed interest rate caps on the product. STATE COMPLICITY ENCOURAGED?– For example, - deposits by state and local governments at US Bank in the State of Ohio are being used to fund the same payday lending for which they recently passed legislation to severely restrict. http://www.usbank.com/checking/caa/agreement.html Applicable Law You understand that we are a national bank located in Ohio. The law that will apply to this Agreement as to issues related to interest and related charges will be the law of the State of Ohio. PERVERSE INCENTIVES – Any compensation program that benefits employees as they exploit the poor. Executive compensation is finally being reviewed but shareholder votes are not binding. GOOD FINANCIAL ADVICE? Banks are deceiving the public that they provide “Good Financial Advice” because they have no duty to give any good advice to the average person that enters their building! Can they explain why customers of their trust department, where “fiduciary financial advice” is given, would find that the payday loan product could never be discussed; the customers of their securities sales staff. would receive a different standard of advice focusing on suitability which includes full disclosure of incentives for the sale of anything; but, the customers of the bank that is “advertised to the public” are really subject to “Cave

FrankRauscher Posted On 5/18/2012 10:57:49 AM

final continuation: and there are no consequences if you do not give good advice. And the ABA and CBA are strongly opposed to any higher standard. COMMUNITY REINVESTMENT – How it is good for the community to place payday borrowers in a “financial death spiral”. TAXPAYER BAILOUT –AGAIN! – So who supports the needy placed in the “financial death spiral” by banks again? Taxpayers via welfare programs? Yes, the CFPB certainly needs to be fine-tuned. Yet, think of their name - CONSUMER FINANCIAL PROTECTION BUREAU! From whom are we citizens being protected- THE BANKS that have become vampire squids. Until the banking industry can regain it prior stature of trust and respect, the CFPB is needed.

Mr Jones Posted On 5/18/2012 3:56:39 PM

And if we could stop making alcohol people would stop drinking and we could eliminate alcoholism. And if we would outlaw guns people would not shoot and kill each other. And if we could elimnate fast food we could reduce obesisty and billions of dollars of health care costs. And if we could stop people from writing hot checks we could elimnate NSF fees. And if we could bank coke and pepsi, we could reduce diabetes and save a ton of money. And if we could bank smoking we would reduce lung cancer. Wake up America, we need MORE REGULATION!

Steve M Posted On 6/5/2012 3:19:28 PM

Amen to that Tom. Hard to imagine that some of the respondees here believe that "regulation" by any name is goodness. (Remember those Dodd and Frank overseer boys? Good stuff! No greed there. Wink, wink...) It would seem that repetitive listening to "we're from the government, here to help" music (or is that givernment?) can cause loss of sight and memory. There is a difference between sound regulation and those that enable graft and catastrophe. Tom's smelling of the latter in this case is based on wisdom -- if familiar odors are any indication of future performance. One correction: the supreme "unaccountable power" medal is probably still held by the IRS -- what with their unique warrantless search and seizure authority and all.

Steve M Posted On 6/5/2012 4:28:39 PM

Amen to that Tom. Hard to imagine that some of the respondees here believe that "regulation" by any name is goodness. (Remember those Dodd and Frank overseer boys? Good stuff! No greed there. Wink, wink...) It would seem that repetitive listening to "we're from the government, here to help" music (or is that givernment?) can cause loss of sight and memory. There is a difference between sound regulation and those that enable graft and catastrophe. Tom's smelling of the latter in this case is based on wisdom -- if familiar odors are any indication of future performance. One correction: the supreme "unaccountable power" medal is probably still held by the IRS -- what with their unique warrantless search and seizure authority and all.

Frank The CFA Posted On 6/11/2012 3:44:10 PM

Oh, the poor babies. Listening to all the whining from folks who were 'conned' into using credit cards, borrowing money, or thinking that other people and banks and shareholders should GIVE THEM STUFF FOR FREE (like ATM money, free checking, etc). I wonder how many of YOU would want to provide free services under government order.

Doug Sr. Posted On 1/26/2014 8:10:52 PM

the CFPB must be closed down at once , they waste billions and all they care about is them selves, money and power. They have and will lie when the truth will do. They have hurt us so bad that i filed a law suit against them in the SD White Plains NY Federal Court # 13-CV-0923. They are one of the most dysfunctional, neglectful, unaccountable and financially irresponsible government agency in America. Thank you Doug Sr.

Doug Sr. Posted On 1/26/2014 8:13:36 PM

the CFPB must be closed down at once , they waste billions and all they care about is them selves, money and power. They have and will lie when the truth will do. They have hurt us so bad that i filed a law suit against them in the SD White Plains NY Federal Court # 13-CV-0923. They are one of the most dysfunctional, neglectful, unaccountable and financially irresponsible government agency in America. Thank you Doug Sr.
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