The Consumer Financial Protection Bureau is a government agency like no other. Not only is the agency responsible for enforcing consumer financial protection laws, it also oversees the practices of bank and non-bank consumer financial institutions alike. With such a wide purview to regulate the economic lives of all Americans, one would assume that the CFPB would operate under some sort of supervisory board like the Securities and Exchange Commission or Federal Trade Commission, or that its funding would be controlled directly by Congress like other market regulators. But none of that is true. And that’s a problem. This means that where the CFPB engages in regulatory overreach or ma
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