Tuesday, August 11, 2009

Tweak to the Proposed Consumer Financial Protection Agency Act

Wonks are Fine, but please, No More Wankers!


The Proposed Consumer Financial Protection (CFPA) Legislation lays out three major arms for the proposed Agency: research, rule-making and enforcement. My only tweak to the Act as currently drafted would be to more clearly spell out required feed-back loops among these arms, namely by ensuring that research is geared toward informing the rule-making process. Every research paper generated should have a cover page outlining the regulatory implications, rules affected and/or new rules proposed. Data sets created by the Agency in its course of examining and supervising the financial industry (redacted or coded as necessary for confidentiality) can be farmed out to Universities and think tanks who are in the business of producing high-quality theoretical research.

For a more complete and informed analysis of the CFPA as a whole, I'd recommend this article and research report by Adam Levitin Credit Slips: The Consumer Financial Protection Agency.

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