While it is difficult to identify a single provision of Dodd-Frank as the absolute worst of that leviathan, empowering the CFPB to determine its own funding needs, outside the control of Congress, surely ranks in the top 10. Regulatory agencies are not supposed to have their own no-limit credit card.

This ought to be a question for Congress, not for the courts. And if 40 states are sufficiently agreed on the appropriate outcome to join in an amicus brief, it would strongly suggest which way Congress will go.

Does restricting such loans, or making them uneconomical to provide, help poor people or hurt them? It's an important question, and not an easy one. See, e.g., .

It seems that a profit that large should trigger immediate regulatory inquiries. Interesting that it takes nearly five years from the trade date to the charges.