Mr. Mulvaney's rethinking of Mr. Cordray's policies illustrates the potential benefits of reconstituting the CFPB from being a bureau led by a single partisan individual to a commission with representatives of both major political parties. With a five-person commission, if the chair of the commission attempts to obtain unanimous votes on new rules, it is far more likely that those rules will reflect a consensus that is likely to survive elections.

Notwithstanding Rep. Waters' dramatic statement, if the guidance is less than a rule, then use of the CRA to withdraw the guidance should be less impactful than use of it to withdraw a rule. The power to do the greater implies the power to do the lesser.

Whatever happens with the SEC's Best Interest Requirement proposal (see ), broker-dealers should pay far more attention to employee training.

Commissioner Piwowar's departure is a significant loss to the Commission. He brought to the SEC the perspective of an economist. As such, he consistently championed the relationship between a strong securities market, sensible financial regulation and economic growth.