I'm not sure whether it's the result of the recent election, the annual end of Daylight Savings Time, or just a general sense that The Fall of Rome, Part Deux is in process, but some of my recent posts are generating some of the best reader emails of my blogging "career." Last night's rant about both the CFPB and the CUNA unleashed the inner Rabid Wolverine of Snark in an in-house lawyer with one of the nation's largest financial institutions, and his screed was too tasty not to share. I'll not identify him or her, or their institution, but rest assured, when it comes to the CFPB, they feel our pain.
From what I've seen I think the CFPB is completely overwhelmed by Franken-Dodd. Their exam requests border on the absurd, and their ability to digest basic information would make anorexics envious. You can tell they have few, if any, people with industry experience, and damn few with entity-level exam experience driving this carousel. If we can devote platoons of lawyers, compliance people and others to these exercises in scatological rendering and barely keep up, I have the deepest sympathies for the smaller shops.
In my own view, the CFPB will prefer to herd a few "bigger cats" than develop rules and processes to meet the community banking world's needs or capabilities. While the Fed and OCC can offer their crocodile tears, and Congress can fumble around, the CFPB seems especially tone-deaf to the industry. Moreover, I doubt Liz "Hunts at Whole Foods" Warren will offer more than 1/32 support for any changes to the mission and/or makeup of the Bureau.
I think an appropriate song for the CFPB would be "Life of Illusion" by Joe Walsh ...
Anyway, I need to get back to my cigar smoking, and flinging, as I churn through CFPB exam requests, but I do enjoy your column.
I click my heels and give a curt Prussian nod to a fellow sufferer nailed to the shattered cross of regulatory tyranny.
Speaking of shattered crosses, did I ever tell you to never mess around with a man in black? No? Well, now I have.