CFPB's Proposed Overdraft Rule Evokes A Dickensian Tale

CFPB's Proposed Overdraft Rule Evokes A Dickensian Tale

January 26, 2024, Law360

One day earlier this month vividly demonstrated that, when it comes to administrative law, Washington, D.C., is reminiscent of Charles Dickens' "A Tale of Two Cities."

For the power of federal agencies, "it was the best of times, it was the worst of times, ... it was the epoch of belief, it was the epoch of incredulity."

The epoch of belief was represented by the Consumer Financial Protection Bureau, which believes it has the authority to issue, as it did on Jan. 17, a significant reinterpretation of a 50-year-old federal statute.