David Hirschmann, the president and chief executive of the U.S. Chamber of Commerce's Center for Capital Markets Competitiveness, has some suggestions for Richard Cordray. In a letter to the CFPB director he "cited concerns about the new 'abusive' standard that was added to the Dodd-Frank Act, along with the already statutory terms 'unfair and deceptive practices,'" writes American Banker’s Rob Blackwell.
"A policy statement defining the term… will help prevent divergent interpretations of the 'abusive' standard," wrote Hirshmann, e.g. state attorneys general and state regulators could bring enforcement actions based on varying standards.
The letter outlined 12 steps (recovery reference intentional?) that the CFPB should take. Among the others was that "the agency should change the way it conducts examinations, including stop bringing enforcement attorneys along as part of the process,' writes Blackwell. Because when you bring the attorneys along from the get-go it
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