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Academy at Rensselaer Education Ctr: Delayed 2 HrsAcademy of the Holy Names: Delayed 2 HrsAchievements & Kids Express Mplwood: Delayed 2 Hrs, no before careAchievements St Kateri Tekakwitha: Delayed 2 HrsAchievements and Kids Express TBGC: Delayed 2 HrsAdirondack Enrichment: Delayed Until 12:30pAesthetic Science Institute: Delayed 2 Hrs, Classes begin at 11 amAlbany Leadership Charter High: Delayed 2 HrsAmbleside School: Delayed 2 HrsAmsterdam City SD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastAmsterdam Head Start: Delayed 2 Hrs, Staff ReportAn Nur Islamic School: Delayed 2 HrsAndes CSD: Delayed 2 HrsArgyle CSD: Delayed 2 HrsArkville Head Start: ClosedAugustine Classical Academy: ClosedAustin's School of Spa Technology: Delayed 2 Hrs, Staff ReportAverill Park CSD: Delayed 2 Hrs, No AM BOCESAverill Park Pre School: Delayed 3 Hrs, No AM Pre-School, No AM PgmBallston Spa CSD: Delayed 2 HrsBattenkill Community Services: Closed, Hockey game still on, will call with timesBennington County Meals: Open, Home delivery delayed Cafe openBerkshire Country Day School: Delayed 2 HrsBerlin CSD: Delayed 2 HrsBerne-Knox-Westerlo CSD: Closed, Offices are closed.Best Fitness (Schenectady): Delayed, No Morning Classes, Club Open No morning classes classes resume 430pBethlehem CSD: Delayed 2 Hrs, No AM BOCESBethlehem Children's School: Delayed 2 HrsBluebirds' Nest Preschool: ClosedBroadalbin-Perth CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No Breakfast, No PTECH, AgTECH, TEC-SMARTBrown School: Delayed 2 Hrs, No Morning PLUS ProgramBrunswick (Brittonkill) CSD: Delayed 2 HrsBrunswick Children's Academy: Delayed 2 HrsBurnt Hills-Ballston Lake CSD: Delayed 2 Hrs, No AM BOCES, 2-hour delay (final)Butterfly Dreams Daycare: Delayed 2 Hrs, Opening at 9:30 amCOARC Adult Transportation: Delayed 2 HrsCairo-Durham CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESCalvary Preschool: ClosedCanajoharie CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESCapital Reg Career & Tech (Albany): Delayed 2 Hrs, No AM BOCESCatholic Central HS: Delayed 2 HrsCatholic Schools Office: Delayed 2 Hrs, Principals Meeting at 10:30Catskill CSD: Delayed 2 Hrs, No AM Pre-KCenter For Early Learning: ClosedChatham CSD: Delayed 2 HrsChatham Kids Club: Delayed 2 Hrs, Open at 8:30Childhood Friends Inc.: Delayed, We will open at 9:00am for All children today!Christ Our Light Catholic Church: Delayed 2 Hrs, Office opening & Adoration delayed 2 hrs. Morning services cancelledChrist the King Early Childhood Ctr: Delayed 2 Hrs, All programs open @ 9:30 AMChristian Brothers Academy: ClosedCircle Of Friends (Delmar): Delayed 2 Hrs, Wrap around delayed 2 hoursCircle of Friends (Ravena): Delayed 2 Hrs, 2.5 hour class is closed 5 hour classes delayedCobleskill Campus Child Care Center: Delayed 2 Hrs, Open at 9AMCobleskill-Richmondville CSD: Closed, Offices Open at 9 a.m.Cohoes City SD: Delayed 2 HrsColonie Youth Centers: Open, No BSPColumbia Christian Academy: Delayed 2 HrsCommunity Library Cobleskill, NY: ClosedCooperstown CSD: Delayed 2 Hrs, No AM BOCESCorinth CSD: Delayed 2 Hrs, No BreakfastCoxsackie-Athens CSD: Delayed 2 Hrs, No AM BOCES, No BreakfastCrossFit Schenectady: Delayed, No Morning ClassesCrossroads Center for Children: Delayed 2 Hrs, Day Care open @ 9:00Crown Point CSD: Delayed 2 HrsDelaware Academy CSD at Delhi: Delayed 2 HrsDoane Stuart School: Delayed 2 HrsDolgeville CSD: Delayed 2 Hrs, No AM BOCES, No BreakfastDoors of Hope: Delayed 1 HrDuanesburg CSD: ClosedEarly Childhood Learning Ctr: Delayed 2 HrsEarly Childhood Education Center: Delayed 2 HrsEarly Childhood Education Ctr-Troy: Delayed 2 HrsEast Greenbush CSD: Delayed 2 HrsEco Baby Daycare & Preschool: Delayed 2 HrsEdinburg Common SD: Delayed 2 HrsExecutive Woods Childcare: Delayed 2 HrsFaith Bible Academy: Delayed 2 HrsFirst Friends Nursery School: Delayed, No AM Program, Enrichment program begins at 1130amFonda-Fultonville CSD: Delayed 2 Hrs, No AM BOCESFort Plain CSD: Delayed 2 Hrs, No AM BOCES, Elem recognition breakfast moved to ThursdayFranklin County Technical SD: Delayed 2 HrsFulmont St Johnsville Head Start: Delayed 2 Hrs, Staff ReportFulton-Montgomery CC: Delayed 2 Hrs, Campus will open at 10 am.Gabriel Abbott Memorial School: Delayed 2 Hrs, No morning daycareGalway CSD: Delayed 2 HrsGeorge Washington School: Delayed 2 HrsGermantown CSD: Delayed 2 HrsGilboa-Conesville CSD: ClosedGlens Falls City SD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESGlens Falls Common SD: Delayed 2 Hrs, No BreakfastGlens Falls Head Start Center: Delayed 2 HrsGloversville City SD: Delayed 2 HrsGood Ground Christian School: Delayed, No AM Pre-K, Afterschool program onlyGrapeville Christian School: Delayed 2 HrsGreen Island UFSD: Delayed 2 Hrs, No BreakfastGreen Tech High Charter School: Delayed 2 HrsGreenberg Child Care Center: Delayed Until 9:30aGreenbush Child Caring: Open, No AM ProgramGreene County YMCA: Open, No Morning ClassesGreenfield Public Schools: Delayed 2 Hrs, No AM Pre-KGreenville CSD: Delayed 2 HrsGreenwich CSD: Delayed 2 Hrs, No AM BOCESGuilderland CSD: Delayed 2 Hrs, No AM BOCESHFM Career & Tech Center: Delayed 2 HrsHadley-Luzerne CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastHappy Kids Day Care Center: Delayed 2 HrsHawthorne Valley School: Delayed 2 HrsHelderberg Christian School: Delayed 2 HrsHelping Hands Pre-School: Delayed, No Morning ClassesHoly Spirit School (East G'Bush): Delayed 2 HrsHometown Health Center: Delayed 2 HrsHoosick Falls CSD: Delayed 2 HrsHope 7 Community Center: Open, 9am-6pm, Reg. After School Food Pantry Open9:30a-11:45Hudson City SD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No Breakfast, No tutoring centerHunter-Tannersville CSD: Delayed 2 Hrs, No AM BOCESIchabod Crane (Kinderhook) CSD: Delayed 2 HrsImmaculate Conception (Glenville): Open, 9:00 am mass cancelledIndian Lake CSD: Delayed 2 Hrs, No AM Pre-K, No BreakfastInlet Common SD: Delayed 2 HrsJohnstown City SD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESJubilee Child Day Care Center: Delayed 2 HrsKid Kampus: Delayed 2 Hrs, Opening at 8:30AMKidsFirst Childcare Center: Delayed 2 HrsKim's Kids Daycare: Delayed 2 Hrs, No BreakfastKingsbury Seventh-day Adventist Sch: Delayed 2 HrsKingston City SD: Delayed 2 Hrs, No AM BOCES, Kingston SD is on a 2 hr delay no AM BOCESLa Salle Institute (Troy): Delayed 2 HrsLakeside Nursery School: Delayed, No AM Pre-SchoolLansingburgh CSD: Delayed 2 Hrs, No Breakfast, Lansingburgh CSD is operating on a 2 hour delayLatham Christian Academy: Delayed 2 Hrs, No AM KLearning To Know Educational Center: Delayed 1-1/2 HrsLexington Center Fulton Co ARC: Open, No TransportationLiberty Ent/ Montgomery Co. ARC: Delayed 2 HrsLife Kids Before/ After School: Open, No AM ProgramLifeSong Inc (Saratoga): Delayed 1 HrLifeSong Inc (Schenectady): Delayed 1 HrLifeSong Inc. (Albany): Delayed 1 HrLifeSong Inc. (Rensselaer): Delayed 1 HrLil' Lambs Christian Daycare Inc.: Delayed 2 HrsLit'l Steps Pre-School: Closed, No AM Pre-KLittle Feet Daycare Center: Delayed 2 HrsLittle Tot Nursery School: Closed, No AM Pre-KLiving Res DCOP (Albany): Delayed 1 HrLiving Res DCOP (Rensselaer): Delayed 1 HrLiving Res DCOP (Saratoga): Delayed 1 HrLiving Res DCOP (Schenectady): Delayed 1 HrLong Lake CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastLoudonville Christian School: Delayed 2 HrsMalta Montessori School: Delayed 2 Hrs, No Toddler Class, No Toddler ClassMargaretville CSD: Delayed 2 HrsMayfield CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastMechanicville City SD: Delayed 2 Hrs, No BreakfastMekeel Christian Academy: Delayed 2 Hrs, No AM Pre-SchoolMenands UFSD: Delayed 2 Hrs, No BreakfastMiddleburgh CSD: ClosedMillbrook CSD: Delayed 2 HrsMohawk Trail Regional SD: Delayed 2 HrsMohonasen CSD: Delayed 2 Hrs, No AM BOCESMontessori School (Schenectady): Delayed, No AM Program, opens at noon, School will open at noon for PM programming.Montgomery County Office for Aging: Delayed 2 Hrs, Advisory Council cancelledMorning Star Learning Center: Delayed 2 Hrs, stay tuned, be safeMother Teresa Academy: Delayed 2 Hrs, No AM Pgm, No am nursery program, School opens at 9:45amMountain Road School: Delayed 2 Hrs, No Before School Care.Mt Moriah Academy: Delayed 2 HrsMyers Education Center: Delayed 2 Hrs, 12 month offices 2 hour delayN. Greenbush Little Red School: Delayed 2 HrsNew Lebanon CSD: Delayed 2 HrsNew Paltz CSD: Delayed 2 HrsNewmeadow at Malta: Delayed 2 HrsNewmeadow at Queensbury: Delayed 2 HrsNiskayuna CSD: Delayed 2 HrsNorth Colonie CSD: Delayed 2 HrsNorthville CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastNotre Dame-Bishop Gibbons: Delayed 2 HrsO.K. Kids, Inc.: Delayed 2 HrsOak Hill School: Delayed 2 HrsOhav Shalom Nursery School: Delayed, No AM Program, No am care for Ohav Shalom school starts at 930 staff report 900 amOnteora CSD: Delayed 2 Hrs, No AM BOCESOppenheim-Ephratah-St Johnsville SD: Delayed 2 Hrs, No AM BOCESOur Lady of Victory Early Childhood: Delayed 2 Hrs, No AM Pre-KOur Savior's Lutheran School: Delayed 2 Hrs, No AM K, No AM Pre-SchoolOur World Montessori: Delayed 2 Hrs, Open at 10:45 a.m.Owen D. Young CSD: Delayed 2 Hrs, No AM BOCESParsons Early Head Start Day Care: Delayed 2 Hrs, Staff report at 9:00 AMParsons Early Learning Center: Delayed 2 Hrs, Staff report at 9:00 AMPerth Bible Christian Academy: Delayed 2 HrsPine Plains CSD: Delayed 2 Hrs, No AM BOCESPineview Comm Church Pre-School: Delayed 1 Hr, open at 8:30Prospect Center: Delayed 2 HrsPumpkin Patch (Albany): Delayed 2 HrsQueensbury UFSD: Delayed 2 Hrs, No AM BOCESQuestar III BOCES - Sarah's Sisters: Delayed 2 HrsQuestar III Catskill Academy: Delayed 2 HrsQuestar III Columbia-Green Ed Ctr: Delayed, No AM BOCES, 2 HR DelayQuestar III Rensselaer Academy: Delayed 2 HrsQuestar III Rensselaer Edu Ctr: Delayed 2 Hrs, Q3 New Vision is closedQuestar III Sackett Educational Ctr: Delayed 2 HrsRavena-Coeymans-Selkirk CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESRed Hook CSD: Delayed 2 HrsRensselaer City SD: Delayed 2 HrsRhinebeck CSD: Delayed 2 HrsRiverRun Community Montessori: ClosedRoots and Wings Montessori: Delayed 2 Hrs, No before care. Open 9:30Rosa Venerini Early Childhood Cente: Delayed 2 Hrs, No AM Pgm, No am classes or beforecare School opens at 11amRoxbury CSD: Delayed 2 Hrs, No AM K, RCS is now delayed 2 hrs - roads are in worse shape then expected. Stay off the side roads until treated , drive carefully today January 18Sacred Heart School (Troy): Delayed 2 Hrs, TSL will open at 9:00amSalem CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCES, No BreakfastSaratoga Academy Arts & Science: Delayed 2 HrsSaratoga Bridges: Delayed 1 HrSaratoga Central Catholic HS: Delayed 2 HrsSaratoga County Senior Meals: ClosedSaratoga Independent School: Delayed 2 Hrs, No AM Pre-K, No Before CareSaratoga Springs City SD: Delayed 2 HrsSaugerties CSD: Delayed 2 HrsSchalmont CSD: Closed, Level 1 ClosureSchenectady City SD: Delayed 2 Hrs, No AM Pre-KSchenectady Jewish CC Day Care: Delayed, Opening at 8:30 amSchenevus CSD: Delayed 2 HrsSchodack CSD: Delayed 2 HrsSchoharie CSD: ClosedSchoharie Career and Technical Scho: ClosedSchoharie County ARC: Open, Buses on Snow Routes, Staff report regular time Public bus aides report regular timeSchoharie County Com. Action Prg.: Delayed 2 HrsSchoharie Cty Child Dvp Cobleskill: Closed, No AM Pre-K, No AM Head Start, HS & EHS closedSchoharie Cty HeadStart (Schoharie): Closed, HS & EHS closedSchool's Out, Inc.: Open, No AM ProgramSchuylerville CSD: Delayed 2 Hrs, No AM BOCES, No BreakfastScotia-Glenville CSD: Delayed 2 HrsSharon Springs CSD: ClosedShenendehowa CSD: Delayed 2 Hrs, No AM K, No AM BOCESShooting Stars Nursery & After Sch.: Delayed 2 Hrs, No AM Pre-School, Will open at 9amSkidmore Early Childhood Center: Delayed, No AM Pre-SchoolSouth Colonie CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESSouth Glens Falls CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESSouthern Adirondack Edu Ctr: Delayed 2 Hrs, 12 month offices 2 hour delaySouthern Berkshire Regional SD: ClosedSpa Christian School: Delayed 2 Hrs, No AM K, No AM Pre-KSpotted Zebra Learning Center: Delayed 2 Hrs, SZ opens at 9:30 Program begins at 10:30 K Program begins at 11:00St Ambrose School: Delayed 2 Hrs, No AM PgmSt Anne Institute: Delayed 1-1/2 Hrs, Staff Report, No Trans, No school for day service StudentsSt Clement's Regional Catholic Sch: Delayed 2 Hrs, No AM Pre-K, No AM Pre-SchoolSt Edward's Church: Delayed 2 Hrs, No Mass and morning activitiesSt George's School: Delayed 2 Hrs, No AM Pre-School, AEP will begin at 11 amSt Gregory School: ClosedSt Jude the Apostle School: Delayed 2 HrsSt Kateri Tekakwitha School: Delayed 2 Hrs, No AM Pgm, No BreakfastSt Madeleine Sophie Pre-School: Delayed 2 HrsSt Madeleine Sophie School: Delayed 2 HrsSt Mary's Academy (Hoosick Falls): Delayed 2 HrsSt Mary's Institute ES (Amsterdam): Delayed 2 HrsSt Mary's School (Ballston Spa): Delayed 2 Hrs, No AM Pre-School, Before Care open at 8:00 amSt Mary's School (Waterford): Delayed 2 Hrs, No AM Pre-KSt Mary's-St Alphonsus Rgnl Cath: Delayed 2 Hrs, No Pre-K No AM Camp KerrySt Mary's/St Alphonsus Noah's Ark: Delayed 2 Hrs, Open at 9:45St Paul's Childhood Center: Open, No AM Pre-K, Part-day room closed only. Extended-day rooms open.St Pius X School: Delayed 2 Hrs, No AM Pre-KSt Stephen's Pre-K Acad (Delmar): Closed, No preschool today. After school enrichments are on until further notice.St Thomas the Apostle School: Delayed 2 Hrs, No AM Pre-KStepping Stone Pre & DCC (Albany): Delayed 2 HrsStillwater CSD: Delayed 2 HrsStory Place Preschool: Delayed, Open at 10, before care closedStorybook Academy: ClosedSullivan BOCES: Delayed 2 Hrs, The Adult Program and Offices will open at 10 amSunshine Kids Corner: Delayed 2 Hrs, Opening at 9AMSusan Odell Taylor School: Delayed 2 Hrs, No coffee hourTLC Christian Day Care: Delayed 2 Hrs, No BreakfastTaconic Hills CSD: Delayed 2 HrsTech Valley High School: Closed, Staff report at 10 AM.Temple Israel Nursery and Day Care: Open, No early drop off School starts at 9:00The Albany Academies (AA & AAG): ClosedThe Beagle School: Delayed, No AM Pre-K, No AM Pre-School, All AM programs closedThe Downtown School: Delayed 2 HrsThe King's School: ClosedTiny Tots Early Learning Center: Closed, No AM Pre-School, No AM Preschool PM TBDTri-Village Nursery School: ClosedTroy City SD: Delayed 2 HrsTroy Prep: Delayed 2 HrsTwin Valley Elementary School: Delayed 2 HrsTwin Valley Middle High School: Delayed 2 HrsUMC Daycare Norton Hill: Delayed 1 Hr, No AM Pre-KUnlimited Potential, Inc: Delayed 1 HrVictory Christian Academy: Delayed 2 HrsVoorheesville CSD: Delayed 2 Hrs, No AM BOCES, No BreakfastWSWHE BOCES - Gick Road: Delayed 2 Hrs, 12 moth offices 2 hour delayWWAARC—Albany & Queensbury: Delayed 1 Hr, Staff Report Regular TimeWaldorf School (Saratoga Springs): Delayed 2 Hrs, No 2 day PreKWarren Street Academy - The Bridge: Delayed 2 Hrs, No BreakfastWashington County Nutrition Program: Closed, No Senior Meal Sites ; No Home Delivered MealsWaterford-Halfmoon UFSD: Delayed 2 Hrs, No BreakfastWatervliet City SD: Delayed 2 HrsWebutuck (Northeast) CSD: Delayed 2 HrsWesley Evergreen Adult Day Program: Delayed 2 HrsWest Canada Valley CSD: Delayed 2 Hrs, No AM Pre-K, No AM BOCESWheelerville UFSD: Delayed 2 HrsWhispering Pines (Cobleskill): ClosedWhispering Pines - Schoharie UPK: ClosedWhispering Pines Pre Sc (Amsterdam): Delayed 2 Hrs, No AM Pre-KWhispering Pines Pre-sch (Delanson): ClosedWhispering Pines Presch - Boulevard: Delayed 2 Hrs, No AM Pre-KWhispering Pines Preschool at Meco: Delayed 2 Hrs, No AM Pre-KWilton Baptist Academy: Delayed 2 HrsWindham-Ashland-Jewett CSD: ClosedWonderland Nursery School: ClosedWoodland Hill Montessori School: Delayed 2 Hrs, Delayed 2 hours . No early care. No toddler AM session, delayed 2 hours. No early care. No toddler AM sessionWorcester CSD: Delayed 2 Hrs, No AM Pre-KWynantskill UFSD: Delayed 2 HrsYMCA (Bethlehem): Open, No Morning ClassesYMCA (East Greenbush): Open, No Morning Classes, Child Watch opens at 9am, Before School Care 6:45amYMCA (Greater Glenville): Open, No AM classes before noon.. No babysitting before noon.YMCA (Guilderland): Open, No AM Pre-School, No Morning Classes, No AM branch childcareYMCA (Schenectady): Open, No Morning Classes, Child Watch Closed for AMYMCA (Troy): Open, No Morning Classes, Child Watch opens at 9amYMCA Southern Saratoga: Open, No Morning ClassesYWCA of Schenectady Children's Ctrs: Delayed, YWCA child care @SCCC delay Until 8am. WA site delayed Until 9am

Ending so-called ‘mortgage kickbacks’ won’t help borrowers

Ending so-called ‘mortgage kickbacks’ won’t help borrowers

The Consumer Financial Protection Bureau is right that mortgage reinsurance arrangements are really

On April 4, the Consumer Financial Protection Bureau announced that it had taken “enforcement actions to end what the bureau believes to be improper kickbacks paid by mortgage insurers to mortgage lenders in exchange for business.”

The kickbacks take the form of dividends paid by captive reinsurers that purport to be a risk-sharing device but are in fact a method of paying lenders for the referral of business. “Illegal kickbacks distort markets and can inflate the financial burden of homeownership for consumers,” said CFPB Director Richard Cordray.

CFPB is right that mortgage reinsurance arrangements are really kickbacks for the referral of business, but it is wrong in suggesting that eliminating them will reduce costs to borrowers. In my view, it is just as likely, perhaps more likely, that the cost to borrowers will increase.

Borrowers have been overpaying for mortgage insurance over the years, and also for title insurance and property appraisals, and the underlying reason is the same. In all three markets, the seller of the service is selected by the lender but the cost is paid by the borrower. This situation inevitably raises prices to borrowers relative to what they would be if the sellers had to compete directly for the patronage of the borrowers who pay for the services.

Buyers beware

When sellers are selected by borrowers, selection is largely based on the price of the service. When sellers are selected by lenders, selection is based on whatever things of value the seller can bestow on the lender, who is largely indifferent to the price paid by the borrower.

Payment of dividends from a reinsurance affiliate is only one method used by mortgage insurers to compensate lenders for referrals. Smaller lenders are compensated by free services, including free loan underwriting, which can be justified on the grounds that the insurer has to underwrite for its own protection.

In the case of title insurance and appraisals, the most common device used to compensate lenders for the referral of business is shared ownership of the title agency or the appraisal management company to which the lender refers its business. If done by the book, meaning that they do the work of such an agency and are not obviously shams, these arrangements are legal.

From the standpoint of the service sellers, all such arrangements are marketing expenses, which must be covered by the prices they charge borrowers. Shutting down one particular method of compensating lenders for business referrals forces them to adopt other devices that could well be more costly. If so, prices will rise rather than decline.

The key to price reductions for borrowers is to force service providers to compete in terms of the price paid by borrowers, as opposed to competing in terms of bribes paid to the lenders who select them. There is a little bit of price competition going on now in the title insurance market, where astute borrowers are shopping for their own deals online. In the mortgage insurance and property appraisals markets, however, there is nothing happening and little prospect that anything will happen without a major change in the rules.

Changing the rules

The needed rule change is extremely simple, and also extremely logical. The rule should be that any service required by lenders as a condition for the granting of a mortgage should be paid for by the lender, with the cost embedded in the price of the mortgage. In one swoop, this rule would replace competition in the bribes paid to lenders with competition in the prices paid by lenders.

If you are not convinced that this rule change would benefit borrowers, consider this hypothetical: Suppose new automobiles were sold without tires, and that to get tires you were directed to a tire agency approved by the dealer, who would add the price of the tires to his bill. Is there any doubt that the price of the car plus tires would be higher than the price now that includes the tires?

And don’t overlook the free bonus. The existing set of complicated rules establishing the legality or illegality of various ways that lenders compensate service providers would be eliminated.

I doubt that CFPB has the legal authority to make this change now, but it can and should ask Congress for the authority it needs to do the job for which it was chartered.

Jack Guttentag is professor emeritus of finance at the Wharton School of the University of Pennsylvania.

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