Comment Letter on the CFPB's Notice of Proposed Rulemaking on Legal Standard Applicable to Supervisory Designation Proceedings

My name is Jarrett Dieterle, and I am a legal policy fellow with the Manhattan Institute. In this role, I develop and communicate novel, sound ideas on how to improve America’s constitutional, legal, and regulatory systems of governance. I have testified before Congress and submitted regulatory comments to federal agencies, as well as provided testimony and input to numerous state legislatures. I have authored many policy briefs, articles in journals including National Affairs and the Georgetown Law Journal, and short form commentaries in popular publications such as the New York Times, Wall Street Journal, USA Today, and Washington Post.

I write in support of the proposed rulemaking and to point out the parallels between the Bureau’s supervisory designation authority and other forms of the so-called “shadow regulatory state.”

C. Jarrett Dieterle is a legal policy fellow for the Manhattan Institute.

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