What Do Charles Darwin, Bullseyes, Blind Squirrels And The Consumer Financial Protection Bureau Have In Common?

First, some news: The Designated Transfer Date for the Consumer Financial Protection Bureau is six months from today (July 21, 2011). Reach down and feel the tracks...you should soon begin to feel the vibration.

For most who read this blog, the "Boom" and the "Bust" references in the title are clear enough. For that matter, the reference to "Recrimination" is not particularly mysterious. At least, it is not as mysterious as identifying the right things to focus on during this year (or so) long period whist the CFPB, State banking regulators and the Attorneys General get their feet under them and prepare themselves for the new order in the world of finance regulation. Looking back, we seem to have had a pretty solid go focusing on timely topics and issues, though a few times we may have missed the mark a bit. Regardless, we are not above patting ourselves on the back when our thoughts are later echoed by major news outlets.

Case in point: Two days ago, I gave a talk to a group of in-house counsel from North Carolina about implementation of the CFPB, where it comes from, why it came about and what we can expect going forward. In the course of preparing for the discussion, I found myself thinking about principles of Dawinistic evolution and applying them to the $180 billion/year U.S. consumer finance industry, and the challenges that it is facing in the coming years. I posited that regardless of the efficacy of the CFPB's implementation effort or the scope of its rule-making and new regulatory reach, the industry would evolve, survive and thrive. I also opined that some discrete companies and business models likely would not survive...for that is the harsh way of Darwinian evolution. It is messy. I got a couple of questions on that topic at the end of my presentation, which is always good because it indicates that someone was listening. Two days later, in perusing the newest articles on the subject, I came across this great piece in Bloomberg that articulates the same idea in a more discrete and detailed way. So for those of you who may be interested, with six months to go before the July 21, 2011, Designated Transfer Date, the evolutionary process has begun. Now, one could argue that this is evidence that BB&R is a well-evolved blog with the tools to survive. Personally, my impression is that it is way to soon to reach that conclusion, and that for now we should just allow that "sometimes, even a blind squirrel finds a nut."