http://www.heritage.org/research/reports...aims-to-protect

I don’t know Diane Katz or who reads The Heritage Foundation, but I certainly agree with a lot in here.

"The CFPB’s actions are constricting the availability of financial products and services and raising costs—all of which will undermine business investment and consumer credit. Immediate reforms are necessary to impose accountability on the bureau. Ultimately, the CFPB should be eliminated and replaced by coordinated oversight of various enforcement functions among other financial regulators."

It will come home to roost when no one can qualify for a mortgage in a few months... I can't wait to see the outrage then... ;eek:

"The burden of such rules would fall disproportionately upon community banks, which have far fewer resources to reconfigure services. To the extent that the CFPB’s regulatory onslaught overwhelms small banks, their larger brethren will benefit—becoming all the more powerful as community banks close. That is the very outcome that Dodd–Frank supposedly was enacted to prevent. "

Bingo!

Overall, an excellent article. Thanks, Andy!

To the extent that the Bureau is adding requirements that aren't in the law, or failing to use its legal discretion to soften a requirement when the burden on the industry is excessive and the benefit for consumers isn't sufficient to warrant that burden, I agree. But when the Bureau's actions are required by the law, the opprobrium belongs to Congress, not to the Bureau.

It is disingenuous of the article's author to suggest that Congress meant for the DFA to protect community banks. Any regulatory burden on an entire industry cannot help but create survivors and victims. There is precious little in the DFA that is pro-community banking.

You're exactly right, "there is precious little" in DFA.

John is right. As bad as I hate to say it, the CFPB is only doing what congress required, and doing it before we have to comply with no supporting regulations.

So far, I have read and broken down 2224 pages of the final regulations. I have been pretty well impressed with the Bureau's summary and the obvious fact they have taken our industry comments to heart and often are NOT siding with the activist groups. They are showing a concern for the little guy (us).

My time was not wasted commenting on the proposals, in fact, one listed comment from a community bank was verbatum something that I wrote...I kid you not! I will never again think "am I wasting my time commenting?" and I will strive to not use what I hear all too often. "I don't have time to read the proposal, I'll just wait on the final rules". You are hurting no one but yourselves by doing that...change did happen as a result of reasonable arguments. I will say, however, if you comment, don't waste your breath griping and whining...back it up with cold hard facts.

I agree with you RR.

The Bureau does seem to have listened to the comments and made interpretive judgements where possible that are not as stringent as they could have been. Not to say that I think everything went our (community bank) way, but at least they did listen to us.

Also remember that their job isn't to watch out for the banks, it's to interpret and finalize the law as passed by congress and to help protect consumers, among other things.

I know that most of us believe that consumers need to take more responsibility for understanding what they are doing, but the industry hasn't done any favors for itself by continually doing things that I think we might recognize as bad (i.e. some of the OD Charging or No-Doc loans).

Just my thoughs.....