More on Vincent DiLorenzo's Mortgage Market Article and the CFPA

by Jeff Sovern

In October, I posted a link to my colleague Vince DiLorenzo's article Mortgage Market Deregulation and Moral Hazard: Equity Stripping Under Sanction of Law.  I've since had a chance to read the article, and wanted to post an additional comment. The article demonstrates the gulf between Congress's intent in enacting various consumer protection measures--generally, to protect consumers--and the philosophy that underlies the actions of administrative agencies in interpreting and implementing those measures--generally, a much more pro-business, anti-regulatory approach.  Though the article never mentions the idea of a Consumer Financial Protection Agency, it offers considerable support for such an agency by documenting how dramatically existing agencies failed to live up to the legislative intent. 

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