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A New Way to Fund the Consumer Financial Protection Bureau Final Macro.Docx (Do Not Delete) 11/22/2017 10:57 Am A NEW WAY TO FUND THE CONSUMER FINANCIAL PROTECTION BUREAU_FINAL MACRO.DOCX (DO NOT DELETE) 11/22/2017 10:57 AM A NEW WAY TO FUND THE CONSUMER FINANCIAL PROTECTION BUREAU CONRAD Z. ZHONG* ABSTRACT Recent controversies surrounding the Consumer Financial Protection Bureau (CFPB) have revolved around its perceived lack of accountability to Congress and the administration. Notable critics of the CFPB, such as the Chairman of the House Financial Services Committee Representative Jeb Hensarling, have characterized the CFPB as a rogue agency. A key legislation sponsored by Rep. Hensarling is the Financial CHOICE Act, which contained such reforms to the CFPB as subjecting its entire budget to the appropriations process. The CHOICE Act has recently passed the House. Though reform of the CFPB is necessary, subjecting its entire budget to the congressional appropriation process risks undermining its effectiveness and independence as a dedicated federal regulator for consumer financial protection. In this paper, I propose an alternative funding solution to reform the CFPB without substantively changing its powers and structure: the hybrid funding model, with part of the CFPB’s budget self-funded and the balance appropriated by Congress. The hybrid funding model is a pragmatic compromise that allows the CFPB’s valuable mission to be preserved while enhancing its perceived accountability. Under this model, the CFPB will have two types of budget, with each earmarked to providing funding for certain functions of the CFPB. The self- funded budget (the size of which is determined by the CFPB) supports its administrative, operational, and other back-office functions of the CFPB. The congressional appropriations budget (the size of which is determined by Congress) covers costs related to the more politically sensitive activities of the CFPB, including its research, regulatory, supervisory, monitoring, and enforcement activities. The hybrid funding solution aims to provide the CFPB with both agency autonomy and congressional accountability while ensuring that the CFPB has a baseline amount of budgetary resources sufficient for it to maintain its basic operational needs. A NEW WAY TO FUND THE CONSUMER FINANCIAL PROTECTION BUREAU_FINAL MACRO.DOCX (DO NOT DELETE) 11/22/2017 10:57 AM 2 UC Davis Business Law Journal [Vol. 18 TABLE OF CONTENTS I. INTRODUCTION ..................................................................................................... 3 II. THE CFPB’S STRUCTURE, POWERS, AND LIMITATIONS ....................................... 5 A. Structure of the CFPB ............................................................................. 5 B. Powers of the CFPB ................................................................................ 7 1. Regulatory Activities ........................................................................ 7 2. Enforcement Activities ..................................................................... 8 3. Other Functions ............................................................................... 11 C. Limitations of the CFPB ....................................................................... 12 III. LEGAL CHALLENGES TO AND REFORMS SUGGESTED FOR THE CFPB ............... 12 IV. THE HYBRID FUNDING MODEL ........................................................................ 16 A. Reasons for adopting the hybrid funding model ................................... 17 1. Changing the CFPB’s leadership structure does not adequately check against arbitrary decision-making by the CFPB ................. 17 2. Subjecting a significant portion of the CFPB’s budget to congressional appropriation makes the CFPB more accountable and less able to engage in arbitrary decision- making ........................................................................................... 18 3. The hybrid funding model is a pragmatic compromise that allows the CFPB’s valuable mission to be preserved while enhancing its perceived accountability .......................................... 19 B. Mechanics of the Hybrid Model ............................................................ 21 1. Self-funded bucket .......................................................................... 21 2. Congressional appropriations bucket .............................................. 23 3. Source of funding for the hybrid model .......................................... 27 C. Evaluation of the Hybrid Model ............................................................ 31 V. CONCLUSION .................................................................................................... 32 A NEW WAY TO FUND THE CONSUMER FINANCIAL PROTECTION BUREAU_FINAL MACRO.DOCX (DO NOT DELETE) 11/22/2017 10:57 AM Ed 1] A New Way to Fund the Consumer Financial Protection Bureau 3 I. INTRODUCTION Since its inception in 2010, the CFPB has played a preeminent role in the federal regulatory landscape and, in the process, has generated many headlines and controversies. There are several key characteristics of the CFPB from which it derives its power: its sole Director, whom once nominated and confirmed, can only be removed for cause;1 its broad rule-making authority under the Dodd- Frank Act (DFA);2 its ability to bring enforcement actions before courts or its own administrative law judges;3 and most importantly for the purposes of this paper, its funding, which is guaranteed up to a statutorily-set percentage of the operating expenses of the Federal Reserve System as specified by the DFA.4 The CFPB in its current form is not without its checks and balances.5 Nevertheless, the CFPB has been the target of constitutional challenges as a result of being an independent agency led by a sole Director and having a statutorily fixed budget that is not subject to the annual congressional appropriations process. The latest of these challenges was PHH Corporation v. CFPB, which saw the D.C. Circuit initially rule the CFPB’s current leadership structure as unconstitutional.6 The D.C. Circuit subsequently granted the CFPB’s request for a rehearing en banc on February 16, 2017, vacating its earlier ruling on the constitutionality of the CFPB’s structure.7 The vacated initial opinion, written by Circuit Judge Brett Kavanaugh, demands that the CFPB Director be removable at will by the President of the United States, transforming the CFPB into an executive agency.8 Commentators had mixed reactions to the initial ruling, with * J.D. 2017, Harvard Law School. I am grateful to Professor Howell Jackson and Lauren Semrau for their invaluable comments and guidance on this paper. 1 12 U.S.C. § 5491 (2010). 2 12 U.S.C. § 5511(c)(5) (2010). 3 12 U.S.C. § 5514 (2010); 12 U.S.C. § 5515 (2010); CONSUMER FINANCIAL PROTECTION BUREAU, Administrative adjudication proceedings, https://www.consumerfinance.gov/administrati ve-adjudication-proceedings/ (Nov. 2017). 4 CONSUMER FINANCIAL PROTECTION BUREAU, THE CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT 9 (2016), http://files.consumerfinance.gov/f/201602_cfpb_report _strategic-plan-budget-and-performance-plan_FY2016.pdf. 5 See Adam J. Levitin, The Consumer Financial Protection Bureau: An Introduction, 32 REV. BANKING & FIN. L 322, 355-58 (noting the CFPB’s lack of substantive power in supervision and enforcement); Arthur E. Wilmarth, The Financial Services Industry’s Misguided Quest to Undermine the Consumer Financial Protection Bureau, 31 REV. BANKING & FIN. L. 899, 909-11 (listing limits imposed on the CFPB, including cost-benefit analysis and restrictions on the CFPB’s rulemaking authority). 6 PHH Corporation, et al. v. Consumer Financial Protection Bureau, No. 15-1177, at *8-9 (D.C. Cir. Oct. 11, 2016). 7 Order Granting the Respondent’s Petition for Rehearing en banc, Case No. 15-1177 (Feb. 16, 2017), https://www.cadc.uscourts.gov/internet/opinions.nsf/5D0253C4E25B93FB852580C9005F3 AE1/$file/15-1177-1661681.pdf. 8 PHH Corporation, No. 15-1177 at *18. A NEW WAY TO FUND THE CONSUMER FINANCIAL PROTECTION BUREAU_FINAL MACRO.DOCX (DO NOT DELETE) 11/22/2017 10:57 AM 4 UC Davis Business Law Journal [Vol. 18 some saying that it would have placed significant constraints on the CFPB’s independence,9 and others believing that the vacated remedy would not have made a notable difference.10 Regardless, with the pending en banc rehearing and a potential appeal to the Supreme Court, the future structure of the CFPB is unsettled. To complicate the matter further, in March 2017, the Justice Department filed an amicus brief stating that the exception to the President’s for-cause removal should not apply to a single-headed agency like the CFPB.11 The Justice Department has taken a position adverse to that of the CFPB, which further undermines the latter’s viability during the present administration. Without for- cause removal protection, the head of the CFPB can be removed by the sitting President for any reason, even for one that is entirely politically motivated. Instead of changing the CFPB’s leadership structure, I argue for an alternative solution to make the CFPB more politically acceptable as an independent agency: a hybrid funding model, combining both features of self- funding and congressional appropriations. Under this model, the operational components of the CFPB would be self-funded through a budget determined by the CFPB, while the enforcement and regulatory components would be subject to a budget determined through the congressional appropriations process. The primary source of funding for both the self-funded budget and the congressionally
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