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The Long Term | Business Legislation Today

The Long Term | Business Legislation Today Offered the possibility of protracted litigation about the CFPB’s authority over TLEs, it is really not unthinkable that the CFPB will assert that authority into the forseeable future and litigate the matter to finality; the CFPB can not be counted on to postpone performing this until it offers determined its financial research with regards to payday financing (by which TLEs may not be likely to hurry to cooperate) or until litigation on the recess appointment of Director Cordray was settled. TLEs, anticipating such action, will desire to think about two distinct strategic reactions. In the one hand, looking to protect on their own from direct attacks by the CFPB underneath the “unfair” or “abusive” requirements, TLEs might well amend their company techniques to create them into line with all the demands of federal consumer-protection rules.