The scene: A television studio in Culver City, Calif. Three contestants stand at podiums as a host gives them answers for which they must provide questions as selected from 30 monitors divided into six columns, on which dollar figures are emblazoned.
Host Alex Trebek: His appearance today is ironic, if not metaphorical.
Contestant: Who is me?
That answer/question scenario wasn't likely to take place, but it's awfully difficult not to see the irony in
This was a return appearance for Cordray on the popular game show. He won $45,303 in the 1980s during his first run on the show. He finished second on Wednesday with $5,200.
Lack of Disclosures, Alex
It didn't go down this way, but personally I was hoping Cordray would bring the game to a standstill by challenging whether sufficient info was being disclosed with every question posed. "I'm sorry, Alex, but the way you said that could have been confused by the consumer... um, the contestants," I could just hear Cordray saying. Trebek would then have to comply with new rules requiring clues to include at least several thousand words of additional disclosures, before filling out documentation to prove he had adequately provided aforesaid disclosures.
I envisioned that ultimately no questions would be asked and answered, nothing would be accomplished and Trebek would wander off-stage mumbling about the futility of it all. Now that would seem fitting.
Speaking of the CFPB, I recently included some interesting observations shared by two attorneys with the Atlanta firm Ballard Spahr, John Culhane Jr. and Chris Willis. The two are experts in dealing with the CFPB and offered a forecast on how the agency will be sticking its tentacles into credit unions.In follow-up to
that column , both gentlemen sent me a clarification of some points made on one of their slides. Culhane and Willis clarified that CUs that have less than $10 billion in assets are subject to NCUA, not CFPB enforcement authority. But any company that is a service provider to a substantial number of credit unions is subject to CFPB enforcement authority, regardless of the size of the CUs for which the company provides services. And that authority will allow the CFPB to take a close look at credit union practices. Moreover, if the CFPB has reason to believe that a credit union has committed a material violation of consumer laws, it will notify NCUA and push for appropriate action. And it will be driving the agenda for regulatory scrutiny of the delivery of consumer financial services.
For years credit unions have tried to help members who arrive in a branch desperate and confused over a payday loan they took out in which no number of payments ever seems to shrink the outstanding balance. And CUs have so far failed to find a way to stop payday lenders.One elected official in England believes he has a solution: death. The MacclesField Express reported that Peter Hayes, a councilor who represents Bollington ward, said his official position is "There's no doubt that payday loans are hideous things and we ought to ban them and the people who are promoting them should be taken out into the street and stoned."
I'm pretty sure the "stoned" reference is not to one of the marijuana dispensaries referenced in an earlier column about how some CUs are going to have unforeseen challenges ahead when it comes to doing business with the retail pot operations, especially should that involve collections.That column led to a note from Henry Wirz, CEO of SAFE Credit Union in California, which found itself in a harsh position after it agreed to open accounts for medical marijuana shops in the state (the buzz-kill banks had already said no).
"We regretted it almost immediately," said Wirz. "Marijuana is still an illegal drug at the federal level. So we found ourselves serving a semi-legal business. We found that the dispensary cash volumes were much higher than they first told us they would be. That caused frequent problems for our Bank Secrecy Act compliance and increased the number of SARs we had to file."
Wirz said SAFE spoke with the U.S. Attorney, who sent a letter to dispensary landlords advising they were housing an illegal business and may be subject to forfeiture.
The Last Straw
"That was the last straw for us," said Wirz. "We sent the dispensaries a letter advising them we would close their accounts...I would not open accounts for dispensaries until they become legal under federal law. Otherwise you are in limbo, caught between state, federal and local laws. Not a good place to be."
In short, it's like being in jeopardy.
-Frank J. Diekmann can be reached at
