Looking to 2013

The beginning of 2012 was shaped by uncertainty on two fronts: will the economy finally start back, however slowly, toward growth? And will the proposed CFPB’s director take us, along with the other regulatory bodies, headlong into regulatory conscription where we would have to consider and justify every action in terms of our being responsible for ‘protecting consumers from themselves’? Our answers were delivered in the form of increased activity and aggressiveness by regulators across the board, unabated by the (now dashed) hopes that a Romney victory would bring an end to the piling-on. The economy seems to be continuing its cautious upward crawl, buffeted by repeated threats of Euro-disaster and political standoffs – but upward it continues, and lenders seem to be focusing once again on growing their portfolios which means it won’t be long before delinquencies start to rebound from historical lows.

• transparency of our operations and, more importantly,
• provability of our actions without the kinds of costs and disruption that regulatory audits have raised in the past.  

As we turn our gaze toward 2013, while we are still not without uncertainty (“How much damage will the beltway bobbleheads wreak on the economy before they demur, declare victory and move on to ignoring some other key issue like firearm management?” etc.), there is one thing we can be sure of: the regulatory environment we most feared is fully upon us and isn’t likely to change for several years. So — We have to re-address ourselves in 2013 to the issues of

 

Winners will be the ones who resign themselves to what is (versus wishing for what might have been), and position themselves to thrive despite the extra burdens.