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Starting consumer protection right


My worry isn't that the Obama administration will pass over Elizabeth Warren at the Consumer Financial Protection Bureau and appoint "some banker" instead. My worry is that they'll pass over Warren and choose some gray bureaucrat or friendly ex-congressman instead. A crusty banker who hates a lot of his former colleagues and has the cutthroat, ruthless personality of lots of bankers might be able to attract other ex-Wall Street types and create an interesting agency. Some former bureaucrat can't.

As I argued in this column, when you're creating a new institution, you need to think about creating path dependence among the staff. To simplify a bit, if you get good people in the first place, you'll keep getting good people after that. If not, not. The argument for Warren is that the best young lawyers and consumer advocates revere her and would walk across glass for the opportunity to work with her. There's no second choice with anything close to that allure.

I'm unsurprised that the administration is conflicted on appointing her, however. A lot of economists -- both inside and outside the administration -- think she's too dismissive of the benefits of financial innovation. Business would lose their minds over the appointment. It'd be a tough sell in the Senate. Of course, this was always what the CFPB was supposed to be about: An independent agency housed inside the Federal Reserve so there's a pro-consumer voice to battle it out with the Fed's -- and the rest of the regulatory system's -- natural bent toward banks and financial products.

The case against Warren, in other words, boils down to ambivalence toward the idea of the CFPB. Which makes sense, as it's her idea. That's fair enough, but I'd much rather start by making the CFPB strong and ratcheting it back if necessary than ratcheting it back at the start and pretending we can make it stronger if we need to do so in the future.

Photo credit: Andrew Harrer/Bloomberg.

By Ezra Klein  |  July 16, 2010; 4:34 PM ET
Categories:  Financial Regulation  
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What are the benefits of financial innovation?

Posted by: mschol17 | July 16, 2010 4:54 PM | Report abuse

Its not that she has little appreciate for the benefits of financial innovation, its that she has little appreciation for the need to make a profit, period.

If you consider Consumers Union to have comparable opinions to Ms. Warren (and I do), then we should expect the BCFP to take the ball and run with it. The goal will not be to merely prevent consumer confusion or the like. The goal will be to dictate what can or can not be charged for a wide range of services. Instead of focusing on disclosure, they will focus on fee bans, fee caps, etc. The end result will be a sharp reduction in choice among financial products. Hopefully you will like the "generic" option, because anything else will be prohibited.

Posted by: WEW72 | July 16, 2010 5:01 PM | Report abuse


Paypal, gift cards, paying for stuff with your mobile phone, Visa branded gift cards for those who can't get a real bank account. A few decades ago "innovative" new services would have been ATM cards, 5 years ago on-line banking.

Those are all "innovative" new financial products. And on all the above, you can pretty much count on the fact that with every fee you charge Consumers Union will jump to their feet and scream "HOW DARE YOU!".

Posted by: WEW72 | July 16, 2010 5:09 PM | Report abuse

Why is it relevant that Warren'd be a tough sell in the Senate? Why even bother with the Senate at all? *sarcasm*

If they want her, they'll just recess appoint her. There's a nice, long summer recess just right around the corner. . . .

Posted by: Policywonk14 | July 16, 2010 5:22 PM | Report abuse

@WEW72 : I assume you like the 3 page 4 point font credit agreements written in unintelligible legalese.

I assume you like the 400% interest payday loan companies.

I assume you approve of the $35 overdraft fee for a $3 cup of coffee.

I assume you want the banks to process the largest charges first in hopes of charging you an overdraft fee for each of the small purchases you make instead of the one big one.

I assume you like ATM fees, even though they are cheaper for banks than live tellers.

I for one, don't feel the slightest sympathy for banks and their continuous drive to screw consumers, especially since their abandonment of lending standards and loaning money that they had no reasonable expectation of getting back was a leading factor in the housing and economic crash.

"Those are all "innovative" new financial products. And on all the above, you can pretty much count on the fact that with every fee you charge Consumers Union will jump to their feet and scream "HOW DARE YOU!"."

I think that CU only protests when banks try to sneak super high fees in under the radar for any of these new services. I don't see that Consumers Union has stifled innovation in car design, even though their ratings are used by millions of car buyers.

Posted by: srw3 | July 16, 2010 5:31 PM | Report abuse

I would assume:

1) Her vitriolic interrogations of Geithner in the Congressional Oversight Panel do not inspire confidence among the administration that she would meld well with the no-drama Obama ethos. (Holding tough hearings are not necessarily deal-killers, but having watched a couple of these, her style and tact, I imagine, infuriate Treasury staff.)

2) Does Warren have practical experience running a large organization, such as a bureaucracy? Would she be a strong, competent, effective leader of a bureaucracy? Does she have the managerial skills needed to effectively run a staff? Might she be better in a different, though somewhat prominent, role?

Posted by: js4981 | July 16, 2010 5:35 PM | Report abuse


Consumers Union does not limit itself to the most egregious examples of fees. I've seen their draft legislation on multiple fronts. They are happy with fee bans in many areas. But you prove my point. You, like Elizabeth Warren, have no problem telling people what they can and can't charge for their services.

The FTC and other organizations have long focused attention on misleading advertising. In doing so, they use an "ordinary person" test. Essentially, they want to ensure that people aren't being sneeky. But they are comfortable to let the market operate. I've dealt with the FTC. If you are a bad apple, they will hammer you, but they also are not anti-business.

CU does not like the "ordinary person" test. They focus on the "most vulnerable". Essentially, if the "most vulnerable" could either (1) not understand something; or (2) understand it, but STILL not act in their own best interest; then the practice is improper.

Those are hugely different standards. The second option is the nanny state in high gear (people are too stupid to make rationale choices, so we will make the choices for them). It also hugely limits choice (for some people pricing plan "a" might be better than "b", but if pricing plan "a" is worse for the lowest common demoninator, then it might be banned).

Price-fixing by the government is about as unamerican as you can get, and CU has no problem with it.

Lets say you are a plumber. I'm sorry, but plumbers really take advantage of people. They only call plumbers when they are desperate for help, and plumbers gouge customers with high rates. From now on, plumbers can't charge more than $20 an hour.

How is that different from a bank picking what rate to charge you for an ATM withdrawl?

And all the legalese is there (in the fine print) because of plaintiff's attorneys. You cannot do anything without having explicitly disclosed the possibility that it might happen. So they disclose EVERYTHING that could happen, to cover their butts.

Posted by: WEW72 | July 16, 2010 5:59 PM | Report abuse

I read a fair number of blogs on the economy, both left/right, and NOONE has more respect from a very broad range of informed observers than Elizabeth Warren on issues that pertaining to banking, loans, and working class/middle class Americans.

Symbols are important to the public, not just to potential agency employees. She signifies no special deals to banksters.

As to 'innovation'. Are naked CDS contracts (insurance purchased by fin. orgs when they have no insurable interest) a good thing. Everything is innovation to banksters and hedgies. Even innovative fraud, although they like regular fraud too, especially if they can get the taxpayers to pay for their errors while they take home bonus checks 10x or more than average US wages. Tulip investing was innovation, right? (snark).

If Obama doesn't appoint Liz Warren, the left of the Dem party (the only real Democrats), will exact some electoral pain.

We can't have more banksters or gray nobodies running the financial end of the US government without complete loss of confidence in a fair economic deal for US taxpayers.

Posted by: JimPortlandOR | July 16, 2010 6:29 PM | Report abuse

Paul Volker on financial innovation:

"R. VOLCKER: A few years ago I happened to be at a conference of business people, not financial people, and I was making a presentation. The conference was being addressed by a very vigorous young investment banker from London who was explaining to all these older executives how their companies would be dust if they did not realize the joys of financial innovation and financial engineering, and that they had better get with it.

I was listening to this, and I found myself sitting next to one of the inventors of financial engineering. I didn't know him, but I knew who he was and that he had won a Nobel Prize, and I nudged him and asked what all the financial engineering does for the economy and what it does for productivity.

Much to my surprise, he leaned over and whispered in my ear that it does nothing—and this was from a leader in the world of financial engineering. I asked him what it did do, and he said that it moves around the rents in the financial system—and besides, it's a lot of intellectual fun."

"MR. VOLCKER: I am not sure that I said innovation in itself is a bad thing. I said that I have found very little evidence that vast amounts of innovation in financial markets in recent years have had a visible effect on the productivity of the economy. Maybe you can show me that I am wrong. All I know is that the economy was rising very nicely in the 1950s and 1960s without all of these innovations. Indeed, it was quite good in the 1980s without credit-default swaps and without securitization and without CDOs."

Most of what was cited above was expansion of payment methods to match new information technology. Whether or not true financial innovations such as mortgage securitization or synthetic CDOs have provided any overall benefit to the economy commensurate with their risks is a much more open question. However, I don't think those sorts of questions would be with in the purview of the Consumer Financial Protection Bureau.

Posted by: jnc4p | July 16, 2010 6:32 PM | Report abuse

I'm with jnc4p. I don't think that for economists "financial innovation" means ATM cards. It means subprime mortgages, synthetic CDOs and all the crap you read about in The Big Short.

Posted by: mschol17 | July 16, 2010 6:41 PM | Report abuse

> A lot of economists -- both inside and
> outside the administration -- think she's
> too dismissive of the benefits of
> financial innovation.

I would be very, very curious to learn what the benefits of "financial innovation" are. Particularly the financial "innovation" we experience from 1997-2008.


Posted by: sphealey | July 16, 2010 8:17 PM | Report abuse

Elizabeth Warren must be confirmed for several reasons:

1) She is the vindication - 10 years too late - of Brooksley Born and her valiant efforts to counteract the unopposed deregulatory mania of the late 90s.

2) So long as Larry Summers and Ben Bernanke - one-time opponent of Born, I might add - still have a job in the administration, Warren makes perfect sense as a counterbalance.

3) She freakin' conceived of the idea of an FDA for financial products and would be its best implementer. (This has been mentioned already).

4) Her appointment would be in keeping with Obama's unfolding first-term legislative strategy: pass a sweeping bill that disappoints progressives for lacking statutory certainty but retains the potential to be liberalized by the right appointee/regulators (e.g., Donald Berwick)

Posted by: tcrguy | July 16, 2010 8:41 PM | Report abuse

The first thing financial reform should include; is a revision of the tax code to a progressive income tax with no deductions and no upper limits.

It's time for the ruling class to start paying down the deficit, incurred by the government, that assures their life of privilege.

The self glorification of giving their tax evaded fortunes to charity is fine; AFTER the cost necessary for their success story is paid! Warren Buffet supports higher taxes on the wealthy and will soon start putting his money where his mouth is to make it happen.

Posted by: PPpatriot | July 16, 2010 10:06 PM | Report abuse

"I assume you like the 3 page 4 point font credit agreements written in unintelligible legalese."

More than I like 2,300 page bills written in admittedly larger font but far more frustrating. In any case (presuming this is about a credit card), just pay off your card each month and you won't have a headache. I've never even read an agreement and have to date paid a total of $0 in fees.

"I assume you like the 400% interest payday loan companies."

I don't, and so I don't use them. They're a bad deal. That said, no one is point a guy to these people's heads, and going to a payday lender once or twice a year given your situation might make perfect sense given the alternatives. Someone who gets a payday loan for each paycheck, well, regulation isn't going to save them. In any case, defaults are extremely high and these people have horrible credit.

"I assume you want the banks to process the largest charges first in hopes of charging you an overdraft fee for each of the small purchases you make instead of the one big one."

And like a good consumer you're aware of the practice, and you know what steps to take to avoid it. By the way, auto dealers are exempt from the consumer credit protections - but of course we all know that of all lenders, auto dealers have consumers best interest at heart.

"I assume you like ATM fees, even though they are cheaper for banks than live tellers."

I just googled 'no atm fee checking account' and the second link told me to talk to chuck.

Why should there be a law protecting people from their own laziness? Anyone paying an ATM fee is happier to pay the fee than to spend 15 seconds on a computer to see if any no fee options exist. As an aside, most ATM fees are charged by banks other than your own. I have no sympathy here.

"I for one, don't feel the slightest sympathy for banks and their continuous drive to screw consumers, especially since their abandonment of lending standards and loaning money that they had no reasonable expectation of getting back was a leading factor in the housing and economic crash."

How are you being screwed if you voluntarily use the bank's services? If you are a customer of a place that is screwing you, just don't be a customer. Problem solved.

Banks screwed themselves with reckless lending, but of course government didn't help here either with cheap credit, land use restrictions, a (continuing) history of bailouts, fannie and freddie fueling the bubble and making subprime so profitable, etc. I don't see any regulations requiring 20% down on a home, and yet that by itself would have arguably prevented the crisis.

All of this consumer regulation is garbage. It's just nanny state meddling into an area where any responsible adult can handle the situation as is.

Posted by: justin84 | July 17, 2010 1:14 AM | Report abuse

I recently had a quick chat with one of the Fed presidents and he was really hoping FinReg would pass, but sad it wasn't much stronger. As he put it, "its marginally better than what we have now" which was enough for his support, but he wanted a lot more to be done.

My point is, is that although the Fed is owned by banks and the banks appoint some key people, there are people in the Fed that aren't so pro-banking (but yes, there are some people that are). I think a quick survey of recent Fed staff papers would show that not everyone is so keen on what the financial world has been up to recently.

Posted by: nylund | July 17, 2010 1:56 AM | Report abuse

Product differentiation is a wonderful in common circumstances. But, in credit markets moral hazard and adverse selection are of key concern and they are exacerbated by the myriad of contracts on offer. Moral hazard arises when someone has an incentive to betray the spirit of a contract. Adverse selection occurs when some contract attracts people that are looking to betray the spirit of a contract. Complicated contracts that are costly to parse make these problems symmetric -now both parties worry about the counter party.

Without standard contracts, we land in a situation where litigation resolves more and more complicated disputes, which societally costly. No one firm can establish a "standard contract" because they do not have the authority -and they are better off a variety of contracts, some of which will dupe the less discerning (or less capable).

Of course no-one puts a gun to the head of anyone contemplating a contract. But, from the perspective of policy, we need to think in terms of large number statistics. Occasionally, even decent conscientious people make mistakes. And, it isn't productive to allow certain firms to set traps to garner rents from the mistake makers. In the aggregate, the introduction of traps increases the average time for productive matches to be made (increasing the search costs).

These search costs erode the efficiency of our economy.

Posted by: MGriebe | July 17, 2010 1:42 PM | Report abuse

I am old enough to have experienced life as an adult before the credit card industry was deregulated and the "race to the bottom" began. In those days, pretty much everyone without a lot of negative credit history could obtain VISA and MasterCards, always the same fair interest rate of somewhere around 12%, as well as department store cards and gasoline cards. Banks were more conservative about credit limits, and so it was harder for a consumer to become overextended.

Now the banks allow higher credit limits and subsidize higher risks of certain customers with higher interest rates, which is a big part of the reason our household debt to GDP ratio is so shocking...far more people end up in trouble and funnel a huge chunk of their income into servicing debt. Back before things became so "innovative," banks still made tidy profits, but the fianancial sector did not consume as much of America's wealth as it does today, profiting from enabling people to become slaves to debt.

You can say we are all grown-ups and the "nanny state" should not get in the way of individuals' decisions about banking and credit. Maybe we should legalize all forms of loan sharking under that theory. But I fail to see how the current "anything goes" atmosphere around "innovative" consumer credit leaves society at at large better off.

From a good piece at The Atlantic by Daniel Indiviglio:

"Then, there's the pure finance. The richer you are, the less personal credit you'll need, and the cheaper it will be. The poorer you are, the more expensive your credit, but the more credit you'll feel like you need. So in order to attain the quality of life that popular culture dictates you should enjoy, Americans with low to moderate incomes go into debt. And they're paying relatively high interest rates, which further eats into their relatively lower income, reducing their wealth potential.

So while it's likely that income inequality helped to fuel the credit bubble, the reverse is true as well: additional credit increases income inequality. On a psychological level, it causes Americans with lower income to believe their pay is adequate enough. On an economic level, companies don't feel the need to pay workers more, because their products and services are selling extremely well thanks to credit. On a financial level, the poor and middle class need to rely on more credit to attain an adequate standard of living, which ultimately makes them poorer."

( )

I hope that whoever ends up at the helm of the CFPB does an aggressive job at fighting the worst abuses in the personal finance and consumer credit industry practices.

Posted by: Patrick_M | July 17, 2010 5:25 PM | Report abuse

That's an interesting article Patrick, but I think Daniel gets a few things incorrect.

"The more content you are, the less need you'll feel to try to increase your income."

I think this is true as far as it goes. But I know several worker-consumers, and they always complain about how little they are paid. I always suggest college or GED + college depending on the person involved. I usually get a list of reasons why that wouldn't be the right solution.

I'll say upfront that these guys aren't just lazy. Several of them work 50+ hours a week. It does seem that they feel when it comes to more education near-term cost outweighs the long-term benefits (again, in their own minds). Some people just don't particularly like school. Thus they get stuck in jobs where marginal productivity is low, and with it salaries are low.

I'm not sure credit is the problem, but rather our emphasis on higher education as the gatekeeper to good jobs, instead of on the job training.

Surely scientists, engineers, doctors, historians, lawyers and the like need a lot of education.

But take the typical entry level job in business. Is it really the case that a four year degree is better preparation than four years (or even one or two) interning for low pay at a given company? Lots of what companies need you to know is specific to that company. It's basically impossible to get a decent business job without a bachelors and a 3.0+ GPA from a decent school, although I think nearly all the value of said degree is in signaling to employers that a particular candidate was disciplined enough to obtain the degree.

Posted by: justin84 | July 18, 2010 1:28 PM | Report abuse


"But what if less wealthy Americans couldn't get as much credit to buy as many of the products that firms produce? Their incomes would have to rise. Management and other upper-income employees would have to accept less compensation in order to pay lower-level workers more so their consumption could remain level and sustain firms' profits."

I'm not sure this is correct. It sounds nice, and I believe Henry Ford increased worker pay back in the day using this rationale, but I'm not sure why the typical firm would do this.

The underlying assumption is that if income is increasing being directed towards the upper middle and upper classes, firms will be increasingly unable to sell product.

But the income just went somewhere else - the pockets of the well off aren't a blackhole. Given that increasing salaries at the low end for most firms increases the buying power of, say, 0.1% of total customers, it doesn't seem to follow that any individual company would believe such a policy worthwhile in terms of sustaining sales growth.

Take Wal-Mart. I don't have actual data available, but say Wal-Mart increases the pay of 1,000,000 associates by 30%, so they can buy more stuff from Wal-Mart. Assume Wal-Mart caters to 100,000,000 American consumers. This means that 1% of Wal-Mart's customers will have more buying power. But Wal-Mart operates on thin margins, and so prices rise 10% across the board in order to make ends meet. I think the likely result here is a sales bonanza for Target, but in aggregate lower overall sales at big box retailers because the prices are much higher and such a small subset of consumers saw increase purchasing power. Over the long term, Wal-Marts would probably close and Target would gain a lot of market share.

What is more likely is that more and more upscale products and businesses are created and marketed to match the income trends, or that firms which cater to lower income consumers continue to aggressively push for discounts from suppliers.

There are reasons for increased income inequality, such as technology, globalization/deunionization and credentialism.

Technology has been busy automating low skill / high value jobs, such as in manufacturing. The low skill workers then must take lower paying jobs, and the savings accrue to management and consumers in general.

Globalization/deunionization also matters. While it makes the average person better off, those in cushy, protected jobs are now more likely to be in lower paid jobs.

Tech/globalization also increase the earning power of the the Tiger Woods and LeBron James of the world vis-a-vis the Wilt Chamberlains and Joe DiMaggios.

As high paying low skill jobs slip away, the increasing need to have at least a bachelors to get a decent paying job is a huge roadblock for those who really aren't the studying types, but who in generations past could get high paying factory jobs.

Credit might add to the story, but not in the way Daniel described.

Posted by: justin84 | July 18, 2010 1:41 PM | Report abuse


I agree that a college education is a good thing, and I also agree that it would be good if more employers placed more value on job training and experience than on educational credentials.

While this may be a worthwhile academic discussion for any individual who would like to increase their earning potential, none of that actually relates to the writer's discussion about consumer credit. Many college educated middle class earners have financial troubles arising from too much consumer debt.

"But I know several worker-consumers..."

Good for you. I actually know more than several. In fact, almost all of my friends and relatives work or has worked until retirement, and every one of them consumes.

Posted by: Patrick_M | July 18, 2010 1:57 PM | Report abuse

"Now the banks allow higher credit limits and subsidize higher risks of certain customers with higher interest rates, which is a big part of the reason our household debt to GDP ratio is so shocking."

Patrick, this sounds like you're referring to credit cards here. Consumer debt hasn't increased by a meaningful percent of GDP over the last 30 years. It was about 12.5% of GDP in 1980 and 16% in 2010. Higher, but not drastically so.

If a person can't handle credit, greater availability plus higher rates can certainly be a bad thing for them. However, default rates for credit cards are high, and recovery is always low. The only solution able to lower rates for some is to deny credit to the greater risks. Default rates for credit cards at large banks have been around 10%, and hit 12% in the first quarter.

The primary reason for a high debt to GDP ratio is that credit for mortgages was easier, combined with (and help drove) the housing bubble.

As a percent of GDP, mortgage debt increased from around 33% in 1980 to 75% in 2007.

Financial obligations as a percent of disposable income did get a bit high, but is now back to late 1980s levels, a product of recent low rates and mild deleveraging.

"Maybe we should legalize all forms of loan sharking under that theory."

Even libertarians are against force or fraud. But more available legal credit reduces the need to ever go to a loan shark, who instead of ruining your credit report breaks your legs if you default.

"But I fail to see how the current "anything goes" atmosphere around "innovative" consumer credit leaves society at at large better off."

I don't know a whole lot of people who are worse off because of consumer credit. Most simply get rewards and perks of some sort (although those are probably funded by interchange fees and higher retail prices to some degree). If someone wants to borrow at 20%, then that's their time preference. It isn't mine and I think that can be troublesome, but who am I to judge - they view themselves as better off.

If you want to use law to reduce credit availbility to poor risks, I can live with that (although we might be able to accomplish that to a large degree by not bailing out financial institutions when loans go bad). If that happens, I don't want to hear anyone complaining that some underprivileged group is being denied access to credit and how horrible they are. It will have been a direct consequence of policy.

Posted by: justin84 | July 18, 2010 2:15 PM | Report abuse

justin84, Yes, I know household debt is largely mortgage debt. And yes most of discussion if about consumer debt, like credit cards.

Your consumer debt-to-GDP ratio is interesting on some levels, but it does not really tell the story of how the average family's consumer debt has changed during that period.

Total consumer debt grew nearly eight times in size from 1980 ($355 billion) to 2008 ($2.6 trillion). During that same period, the share of disposable income each household spent servicing its consumer debt and mortgage debt increased by 35 percent. We once accumulated savings by spending less than we made and banking the difference. In 1982, the average household put 11 percent of its disposable income into savings; twenty-five years later that figure had dropped to less than 1 percent.

I know that default rates for credit cards are high, and that is the direct result of card issuers setting credit limits too high and then charging astronomical interest rates to poor risks (or as soon as a consumer misses a payment date). In the 1970's a full-time college student with no real personal income might be given a credit card with a $200 limit, now it is not unusual for them to be given a card with a $3,000 limit or more. The banks want people to "max out" their limits and get stuck.

"I don't know a whole lot of people who are worse off because of consumer credit."

You yourself mentioned that 12% of card holders default, so those 12% are certainly worse off, and for every one of those that actually default there are many more who are not in default but who are funneling all their disposable income into service high interest consumer debt. Talk to a bankruptcy lawyer some time about the effects of credit card practices on personal finances in recent decades.

"I don't want to hear anyone complaining that some underprivileged group is being denied access to credit and how horrible they are. It will have been a direct consequence of policy."

I am not arguing that any "group" should be denied "access" to credit. I am advocating every group have access to an appropriate level of credit at a fair interest rate. That's how the industry once operated, and it was an excellent policy for all concerned.

Posted by: Patrick_M | July 18, 2010 5:01 PM | Report abuse

Consumer protection is already starting off wrong. Before this consumer agency has even formed, expectations of what it will do are very low. There's lots of talk about the agency taking on payday lenders and other marginal financial products, but no talk about regulating the culprits of this last economic mess we're still in. The Fed will be glad to have Elizabeth Warren chasing after payday loans and overdraft fees, because it will allow the unholy union between the Fed and the big banks to continue undisturbed.

Posted by: onexister | July 20, 2010 1:23 PM | Report abuse

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