It is not that often that a new federal financial institution regulatory agency is created, but when it happens one can only hope for something better than what existed before. But the Consumer Financial Protection Bureau (CFPB) continues to disappoint.
The latest disappointment is relatively minor. In their regulatory agenda published last fall the CFPB stated that final rules revising Regulation Z provisions dealing with the borrower’s ability to repay would be published in April 2012. Well, April has come and gone and still no final regulations.
Our biggest concern is the quality of the regulations the CFPB eventually publishes. But do quality and timely delivery have to be mutually exclusive? I have been a witness to 36 years of missed regulatory deadlines. I hoped the CFPB would be better at meeting their own deadlines than their predecessors.
The regulations should be published soon. We have a mountain of Truth in Lending revisions coming – this first piece was scheduled for April, three more pieces are scheduled for July, and another piece for October.
I am not minimizing the challenge that the CFPB has before it; the revisions to Regulation Z are massive. But once a project gets behind schedule it is hard to catch up. Missed deadlines are an honored tradition among federal financial institution regulators. The same old story continues.