About Me

Jonathan Foxx, PhD, MBA is the Chairman & Managing Director of Lenders Compliance Group, the first full-service, mortgage risk management firm in the United States, specializing exclusively in mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks.

Tuesday, September 25, 2018

CFPB goes Global

Who would have thought that in this era of anti-globalism and deep state subterfuge we would see the Consumer Financial Protection Bureau or, if you’d like, the Bureau of Consumer Financial Protection, going global! Well, maybe not global in the sense that the whole world will get involved, but at least eleven financial regulators are jumping on a new initiative which, for United States companies, is run out of the offices of the CFPB. Then again, perhaps the whole world will not get involved, but supposedly enough of the world’s financial regulators will get involved in this willowy scheme for it to somehow make some sense.
Before I get into those plans, a word about the name change from Consumer Financial Protection Bureau (CFPB) to Bureau of Consumer Financial Protection (BCFP). Although the change in the name conforms with the statutory name given the agency, the branding effect is to make “consumer financial protection” play second fiddle to the concept of a mere “bureau.” From a marketing point of view, think of it as a kind of demotion, a blurring of focus, a mangling of an intuitive juxtaposition.
Maybe the name change is an apt decision, since the agency at this time is hardly involved in enforcement and has either throttled down enforcement litigation or cancelled it out altogether. Remember the CFPB’s dispute with Equifax over letting 143 million emails get filched? Iced by the BCFP! Maybe the idea is to leave the enforcement to the states; after all, Equifax has been under investigation by every state attorney general and has faced more than 240 class action lawsuits. In any event, the BCFP doesn’t seem to mind much about the 20,000 complaints from consumers about Equifax’s cyber-breach. I guess they’ll just let the states figure it all out. The Feds have better things to do, like join a global interface!
Anyway, for the time being, I’m still stuck on “CFPB” over “BCFP,” so I’m going with it.
Welcome to “GFIN” – yet another acronym to be added to the great pantheon of acronyms!
It stands for Global Financial Innovation Network. The name contains some modernistic sounding buzz words, such as “global,” innovation,” and “network.” It consists of eleven financial regulators,[i] hence the overly abused word “financial.” I am not sure how to contract GFIN into a monosyllabic word, let alone a polysyllabically pronounceable word, like “Go-Fin” or “Gaf-In” or “Goof-In” or “Gay-Fin” or “Gee-Fin” or “Gy-Fin” – so let’s just say “G,” “F,” “I,” “N,” and hope for the best!
The CFPB has said the new network will seek to provide a more efficient way for innovative firms to interact with regulators by helping them navigate between countries as they look to scale new ideas. Who gets to choose what is and what is not “innovative?” Not yet determined. Maybe “innovative” means “make money for investors” or maybe “innovative” means “less regulations.” This initiative will also create a new framework for cooperation between financial services regulators on purportedly innovation-related topics.

CFPB goes Global

Who would have thought that in this era of anti-globalism and deep state subterfuge we would see the Consumer Financial Protection Bureau ...