With the usual caveat that the opinions I’m expressing are those of a middle-aged insomniac typing away in his hotel room and not necessarily those of the Association for whom he works, here is my take on what’s good, bad and ugly about the CHOICE Act (HR 10) that was marked up and passed by the House Financial Services Committee last Thursday.

The Good

• Making the CFPB’s director an at-will servant of the President.  Under the current structure, the Director is, at best, a benign dictator who acts as the judge, jury and executioner for every federal consumer protection law.  This is just too much power to give to one person and most likely unconstitutional.
• Codifying the requirement for a public hearing on the NCUA’s budget and publicly disclosing the Overhead Transfer Rate – the secret sauce formula NCUA uses to divide up the cost of Share Insurance Fund audits between state and federally insured credit unions.

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