At the American Bar Association’s Annual Meeting in Toronto, I attended a two-hour program on August 6 about the CFPB.  I was disturbed by two things that occurred at that meeting, which made me question again whether the CFPB is as transparent as it says it is. 

First, the CFPB would not permit anyone on

The CFPB presented a report this past Monday trumpeting their accomplishments during the implementation period. And, they mention that they have a memorandum of understanding (MOU) in place with just about every transferor agency or other federal agency (i.e., the FTC) with whom they will be working.

Thanks to the misleadingly “open” design of the