Despite her over-sized vendetta against “snot nosed millennial” bureaucrats over at the CFPB, Executive Editor Heather Anderson's insight into one of the CFPB's biggest flaws, and its most dangerous authorities – UDAAP – is very well founded. With the blanket authority to declare any financial product or service to be “abusive,” the highly-partisan, and ideologically-driven CFPB Director Richard Cordray has the unprecedented ability to distort the marketplace, and to arbitrarily punish political adversaries. Ms. Anderson's concluding warning is as true, as it is chilling – the CFPB could pursue credit unions for violations of UDAAP based upon commonplace lending and collection practices.

I would suggest that former U.S. Senator Phil Gramm articulated the same concern in his July 24th op-ed in The Wall Street Journal entitled “Dodd-Frank's Nasty Double Whammy” when he said, “To limit abuse by the rulers, ancient Rome wrote down the law and permitted citizens to read it. Under Dodd-Frank, regulatory authority is now so broad and so vague that this practice is no longer followed in America. The rules are now whatever regulators say they are. Most criticism of Dodd-Frank focuses on its massive regulatory burden, but its most costly and dangerous effects are the uncertainty and arbitrary power it has created by the destruction of the rule of law. This shackles economic growth but more important, it imperils our freedom.”

The Dodd-Frank Act, and the CFPB that the law created, have continually threatened credit unions' relationship-based business model by imposing a compliance-driven ideology of one-size-fits-all.