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Friday, April 20, 2018


Dennis Wall

Jeff, I too have been wondering about this "$1 Billion" fine. David Dayen wrote a piece that was just published in The Nation magazine. He gives his take on it, and what he says is a good explanation. Wells got over $4 Billion total back so far from the Tax Bill. It wasn't until after that bill passed and Wells got its money that the "fine" was announced. It is still due future tax credits; the $4 Billion figure comes from what Mr. Dayen describes as money on hand right now, more or less. As he points out, Wells has already booked this on its accounts.
By the way, have you noticed that the CFPB has changed its name since Mick Mulvaney took charge? The Consent Order filed on April 20 "In the Matter of Wells Fargo" says "Bureau of Consumer Financial Protection." The word "Bureau" now comes first, the "Consumer" comes after. Even the Administrative File numbering is changed. The Consent Order of April 20, 2018 reflects "2018-BFCP-0001" which makes sense if this is the first enforcement action on Mr. Mulvaney's watch, that the numbering change would reflect that. Contrast this to the CFPB's September 8, 2016 consent order with Wells Fargo, numbered "2016-CFPB-0015."
When did the CFPB change to the BCFP exactly? The first time I have seen it is on the April 20 Consent Order with Wells. Subtle, but not so subtle, to change the emphasis from the Consumer to a Bureau.
Thank you.
Dennis Wall


Good point about debt collection abuses. Not only does public enforcement action in that area complement or duplicate private actions, it may actually undermine the latter and take a revenue stream away from attorneys and law firms that do FDCPA cases.

The same goes for taking time-barred claims out of the bad-debt collection-to-litigation pipeline through auditing programs (as in the case of private student loans under the NCSLT umbrella and TSI, the Trusts' "special servicer" aka debt collector), though it may have been well-intentioned (under Cordray).
See post from last October here:
Wolfgang Demino

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