Revolving Door Regulators


Senator yesterday. Lobbyist today.

Representative yesterday. CEO today.

Cabinet level appointee yesterday. Bank Chairperson today.

Government Agency Director yesterday. Law firm senior partner today.

CFPB Regulator yesterday. Competitor today.



The Inside-Outside Gambit

The Four Horsemen

A Business Model for Former Regulators

Partners in Business

Making a Market in Non-QM


What did they know, and when did they know it?

Extinguishing the Fire



On July 31, 2013, the House Committee on Oversight and Government Reform and the House Committee on Financial Services sent an eight page Congressional letter (Letter) to Richard Cordray, the Director of the Consumer Financial Protection Bureau (CFPB). Signed by a bi-partisan group of Representatives, it expressed concern about the recent departure from the CFPB of four high level officials. The Letter forms the basis of further inquiries by the Committees. Noting a news report, the Representatives indicated it appears that certain officials "have left the CFPB in order to profit from rules they helped create."

Who are these individuals? What were their former CFPB positions?

First, there is Raj Date, former Deputy Director of the CFPB, who left the CFPB on January 31, 2013, shortly after a whole set of Final Rules were issued. (Of course, he gave the unimaginatively standard reason: to spend more time with this family.) Yet a month and a half later he incorporated an "advisory and investment firm,"Fenway Summer LLC" (Fenway), which focuses "on those borrowers who do not meet the standards for 'qualified mortgages' as set by the CFPB under rules." If you would like to know more about this new firm, you can visit its website at (Website)

Promoting himself now as the "first-ever Deputy Director" and the Bureau's "second-ranking official," Mr. Date describes his responsibilities as helping to "steward the CFPB’s strategy, its operations, and its policy agenda."

Next in line are the recruits to the new firm. Mr. Date was joined by three other former CFPB big shots: Garry Reeder, Chris Haspel, and Mitch Hochburg.

Mr. Reeder was the Chief of Staff of the Bureau, where, among other things, he was "directly involved with the creation and establishment of the Research, Markets & Regulations division." (Website)

Mr. Haspel served on the Bureau's Mortgage Markets team as its "senior expert in residential mortgage servicing and securitization;" indeed, he "managed many of the CFPB’s efforts in developing and executing mortgage policy and led Mortgage Markets’ efforts in developing the CFPB’s mortgage servicing rules." (Website)

And then there is Mr. Hochburg, who served on the Mortgage Markets team as another "senior expert in residential mortgage servicing and securitization", in which position he "managed many of the CFPB’s efforts in developing and executing mortgage policy and led Mortgage Markets’ efforts in developing the CFPB’s mortgage servicing rules." (Website)


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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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