The Data-Rights Dilemma: The Balance Between CFPB Despotism and Democracy 

Last week, I despaired of CFPB edicts because I disapprove on principle of despotism no matter how well intentioned.  But, as shown in our in-depth analysis of the CFPB’s request for views on consumer data rights, democratic process can also be disastrous.  In what purports to be an “outline” of 71 pages and 149 questions often including numerous substantive sub-questions, the Bureau has gone back to its old habit of 1,000-plus page rules sure to do far, far more for lawyers than consumers seeking to better control their own financial destinies.

m110722.pdf