The Junkman Cometh

In its effort to combat what it calls “junk fees”, the CFPB conflates advancing consumer protection with curtailing market power.  This won’t work — that which is anti-consumer can take place in a super-competitive market (think subprime mortgages) and that conducted in a market powerhouse (innovative financial-inclusion products) may be very much to a consumer’s benefit.  Thus, if the CFPB makes a muddle of its two worthy goals, it will scramble its policies.  This will create a patchwork of conflicting actions that sometimes put consumers at great risk, sometimes put market integrity in peril, and sometimes do both at the same time.

m020722.pdf