We think two posts by Deepak Gupta that recently appeared on the Consumer Law & Policy Blog make for interesting reading.
Last July, on our blog, we wrote about how the hiring of Mr. Gupta by the CFPB’s Office of General Counsel might impact the CFPB’s position on the use of arbitration in consumer financial services contracts. In the first of his posts, Mr. Gupta discusses his departure from the CFPB earlier this year to start his own appellate litigation and policy consulting practice and makes some observations about his experiences at the CFPB.
In his second post, Mr. Gupta discusses the OCC’s new preemption rule, which (to no one’s surprise) he is highly critical of. (We also have written about the OCC rule, including, most recently, the likely impact of Thomas Curry’s appointment as Comptroller on the OCC’s preemption position.)