Obviously, the financial well-being goal as defined by the
BCFP is laudable.
They are part of the Oklahoma Bankers Association group of about 70 industry executives, who plan to visit the
BCFP, the Federal Reserve and the Office of Comptroller of the Currency, in addition to conversations with Oklahoma's legislators.
"ABA appreciates Acting Director Mulvaney's leadership at the
BCFP and the timely decision to open up the Bureau's policies and procedures to the RFI process," said O'Neill.
This ambiguity is relevant in the case of the
BCFP. The latter is not self-contained, but rather it is housed within the Federal Reserve, "itself an independent, freestanding component of the Executive Branch." (25) However, the
BCFP is arguably independent from and not subordinate to the Federal Reserve, as the latter is prohibited from removing
BCFP employees or intervening in
BCFP matters.
But purely as a matter of informational advantage, the creation of the
BCFP is a welcome addition to the regulatory landscape of consumer finance.
The
BCFP's purpose is to "implement and, where applicable, enforce Federal consumer financial law consistently for the purpose of ensuring that all consumers have access to markets for consumer financial products and services and that markets for consumer financial products and services are fair, transparent, and competitive." (79) To carry out this broad mission, the Act endowed the
BCFP with primary regulatory authority over federal consumer financial laws, including existing laws currently administered by a multitude of federal agencies such as the FTC, Federal Deposit Insurance Corporation, Comptroller of the Currency, and the Board of Governors of the Federal Reserve System.
When Dodd-Frank was finalized on July 21, 2010, Title X (173) contained the provision that established the
BCFP, (174) a novel entity P2P lenders hoped would become the new regulator for the P2P industry.
However, that effort proved unsuccessful and the industry will face oversight by the
BCFP.
The Pentagon has weighed in on the issue, supporting the inclusion of auto dealers under the supervision of the
BCFP and against the amendment over concern that many members of the military fall victim to the practices of predatory lenders.
Mr McGowan, who has been asked by fellow patients to organise a petition, said: "A majority of patients agree that we have never been happier or had more trust in our family practice than since Dr Swain took over on behalf of the
BCFP two years ago.