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The CFPB has been widely criticized for regulating by enforcement actions, rather than embarking on rulemaking proceedings, to delineate the regulatory rules of the road for the financial services industry. In a March 9,2016 speech, Director Richard Cordray endeavored to explain the method to the CFPB’s enforcement madness. While understanding the director’s perspective is helpful, that speech failed to connect all the dots for the compliance world. 

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