The Weekly Standard has just published an article written by attorney and former regulator Ronald L. Rubin that you will want to read.
In the post, Rubin shares his insider experience as a former enforcement attorney with the CFPB, leading one of the Bureau’s first two debt collection investigations. He shares what he understood – and still believes — to be the CFPB’s strategy; generating “dramatic headlines by suing ‘choke points’ – i.e. the leading firms in every consumer financial business.”
This article comes at an interesting time — on the heels of the debt collection SBREFA hearing, a milestone in the years-long rulemaking process, where – it appears – that CFPB staff is expending a great deal of energy to understand the market and its nuances. If Rubin’s accusations are true, the strategy (and intentions) of the rules has already been written.
You can find Ronald Rubin here.