offered the probability of protracted litigation in connection with CFPB’s authority over TLEs, it is really not unthinkable that the CFPB will assert that authority when you look at the future that is near litigate the matter to finality; the CFPB can’t be counted on to postpone doing this until this has determined its economic research with regards to payday financing (by which TLEs can not be anticipated to hurry to cooperate) or until litigation within the recess appointment of Director Cordray happens to be settled.
TLEs, anticipating action that is such will want to give consideration to two distinct strategic reactions.
regarding the one hand, looking to protect on their own from direct assaults by the CFPB underneath the “unfair” or “abusive” requirements, TLEs might well amend their company techniques to carry them into line aided by the needs of federal consumer-protection legislation. Numerous TLEs have previously done this. Continue reading “The Long Run. TLEs, anticipating action that is such will desire to start thinking about two distinct strategic reactions.”