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Certainly, the Bureau’s hesitance to rescind the whole guideline is as a result of issue of conquering “arbitrary and capricious” review because of the courts. Arbitrary and capricious review is a procedure through which a court product reviews an agency’s policymaking procedure to ensure it doesn’t surpass the appropriate bounds of administrative discernment. Simply put, the agency must make provision for sufficient reason for rewriting the guideline.
Rescinding the guideline could be a challenging process, but certainly not insurmountable.
The research underlying the payday rule is deeply flawed as i have outlined in my paper, as well as in regulatory comments. The 2 studies undertaken because of the Bureau to justify the legislation have actually major shortcomings, such as for example their questionable behavioral economics claims, to your level that the legitimacy associated with the whole guideline is under consideration. For instance, as University of Chicago economics teacher Marianne Bertrand and University of Ca, Berkeley legislation teacher Adair Morse have written in their research associated with industry:
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