The Long Run. TLEs, anticipating action that is such will want to think about two distinct strategic reactions.

Because of the possibility of protracted litigation about the CFPB’s authority over TLEs, it’s not unthinkable that the CFPB will assert that authority into the future that is near litigate the matter to finality; the CFPB can not be counted on to postpone doing this until it’s determined its financial research with regards to payday lending (by which TLEs may not be likely to hurry to cooperate) or until litigation throughout the recess appointment of Director Cordray was solved.

TLEs, anticipating such action, will need to start thinking about two distinct strategic reactions.

Regarding the one hand, looking to protect on their own from direct assaults by the CFPB beneath the «unfair» or «abusive» requirements, TLEs might well amend their company techniques to create them into line using the needs of federal consumer-protection guidelines. Les mer