The published outline is consistent with the CFPB's policy of encouraging litigation against financial institutions. It is notable that the CFPB finds many of the identified wrongs to be trivial (at page 3) - so trivial in many instances that consumers do not even know they have been "wronged." Apparently, the CFPB believes that the best way to right such trivial wrongs is to encourage class action litigations. (One may reasonably question the validity of this policy preference.)

One can readily imagine other questions that seem more fundamental than those the OFR is now studying: what impact do low interest rates have on the conduct of financial institutions? What is the viability of the municipal and corporate pension plan system in a prolonged low interest rate environment?  (See in this this regard page B1 of today's New York Times as to the likely insolvnecy of a major private pension plan?)  How do the higher costs of financial regulation affect…

Gemini made an interesting legal/strategic decision to be regulated under "banking" law rather than under the new bitcoin regulatory framework.

Commissioner Gallagher was a thoughtful and serious regulator at the SEC. He took very seriously his responsibility to implement financial regulations that would both protect investors and serve the economy. He was a constant but reasoned critic of the regulatory philosophy that simply argues for "more" (the more regulations, the better). Perhaps the most powerful argument he made against this self-defeating approach was a visual demonstration, represented in a mind-boggling chart, of the…