BOL moderators, we may need to start a thread on this outside of the Cooler. A few of my first impressions:
1. All of the new oversight councils and agencies, notably CPFA, merely ADD TO the existing regulatory burden; there’s nothing said about HUD relinquishing its mortgage oversight role, or FTC relinquishing its privacy/unfair practices role, etc. CPFA is simply ANOTHER layer of regulation.
2. This over-reaching into enforcement areas generally handled by the states, notably mortgage brokers and insurance, is probably unconstitutional – probably not a useful argument except to say that if legislation includes too much over-reaching, it will probably be subject to lengthy legal action.
3. The international stuff sounds nice to the average voter, but – most international financial activity done in the US is already subject to our regulations, and the rest of the proposal is better handled outside of this reform package and negotiated as a treaty for later ratification.
The ABA seems to be spearheading the lobbying, but we BOLers may wish to discuss this further, here and elsewhere....
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