View from CBA June 28, 2013

June 28, 2013

The US Supreme Court's decision to hear the Noel Canning v. NLRB case to determine the constitutionality of President Obama's "recess/non-recess" appointments reminds us the CFPB operates under a continuing cloud of uncertainty for consumers and the industry. Don't expect any clarity until winter at the earliest. Director Cordray's tenure is expected to end on January 4, 2014 -- unless he is named Deputy Director... 

The CFPB bulletin on "responsible conduct" during investigations has been released -- you might want to read it... 

Student lending payment flexibility continues to be of interest on Capitol Hill with Tuesday's hearing -- see our GR update below for a summary. Because of our underwriting standards, private lending has only a 5.3% default rate (and CBA members report much lower rates) while federal loans default at a rate of 13.5%. Our Education Committee continues to work with regulators and customers in an effort to assist those banks in repayment... 

I read this week 76% of all Americans live paycheck to paycheck. I sure hope the OCC, FDIC and CFPB understand many families need short term liquidity products to pay essential bills, and these are best offered within a regulated industry - not a risky "shadow" lender or a local pawn shop... 

Great to see our industry's reputation rebounding. I know our banks have made it a top priority to improve relationships with our customers... 

Enjoyed a visit to West Coast last week to see CB&T and CoreLogic. Irvine, CA is a beautiful city. Only one In-N-Out burger visit.