Friday, November 30, 2012


Okay, so I've started thinking about Rome.  I just got an e-mail saying I would indeed need to provide a certification from a doctor that I am fit to run.  Unfortunately my primary care doctor just moved to Phoenix, so this is going to be a bit of a process . . .

More importantly, I recently had to provide an abstract to Law and Society for a program on comparative consumer law, and I thought to myself, thought I, what time like the present to write an abstract for my Antitrust Marathon presentation.   Here's what I came up with:

Comparative Consumer Financial Protection -- The Allocation of Enforcement Power

The 2010 Dodd-Frank Act created the Consumer Financial Protection Bureau.  One of the goals of the CFPB was to centralize regulatory over consumer financial products in a single agency.  The centralization of enforcement power was less complete, with prudential agencies retaining some enforcement power.  The first task of this paper will be to describe the balance of centralized and decentralized enforcement power within the CFPB.  The second task will be to compare the Dodd-Frank architecture to the enforcement structure used in other countries, both with regard to competition law and with regard to consumer protection (which are frequently handled by the same regulator).  An advantage of centralization is that a single agency is charged with consumer protection (financial or otherwise).  A concern is the enhanced possibility of capture created by a single regulator.  This paper will consider the balancing of these concerns in the US and EU. 

I had told Spencer that I would focus my remarks at the Antitrust Marathon on the CFPB's enforcement power, but any thoughts you all might have on the comparative angle would be most helpful.  

What are you all thinking about??


  1. What am I thinking about? Gelato.
    When I ran the Venice marathon I ate so much of that after the race.....mmmmmmmmmmmmmmmm.
    Soon though I may think about my think-piece on pub/priv enforcement.