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by grellas 3166 days ago
It is entirely superficial to cast this fight as one between good and evil. As much as anything, it was about proper process.

Legislative, executive, judicial - those are the three branches under the Constitution that are supposed to check and balance one another.

The legislature passed the federal arbitration act almost 100 years ago. It was signed into law by the president. And it has been consistently upheld by the U.S. Supreme Court in the face of many and varied court challenges.

In essence, the result of this century-old jostling is a body of duly enacted law that says that binding arbitration clauses are truly binding and therefore can be used in contracts to foreclose judicial proceedings by requiring that disputes covered by such clauses be resolved through arbitration. Moreover, a massive court challenge resulted in a holding of the Supreme Court saying that waivers of judicial class-action rights in favor of arbitration are also binding - meaning, it is neither unjust, unfair, nor against public policy (legally speaking) to say that consumers can be required to waive such rights and be required in all cases to arbitrate their disputes.

Now, one may believe that all of this is repugnant and grossly harmful to consumers. Others may disagree and may in particular believe that class-action lawsuits are primarily vehicles that help the trial bar and do little with their nickel-discount coupons to actually further the interests of consumers. Either way, the existing law is the existing law. The proper way to change it is to gain control of the legislative and executive branches and to repeal or amend the federal arbitration act. In that way, the law could easily and properly be shaped to forbid making arbitration mandatory and binding or limit the ability to use binding clauses in specific areas of law, etc.

The problem with CFPB is that it sought to carve out its own view of what is right and proper for consumers of financial services without regard to the intent of Congress in having enacted the existing arbitration laws. As established, CFPB is not accountable to Congress or any other form of traditional oversight of its bureaucratic functions (its structure was declared unconstitutional by the D.C. court of appeals). It is in that sense an organization that could be characterized as "rogue" based on traditional rules of governance and it is certainly seen as such by those who disagree with its particular actions in using its power to attempt to regulate arbitration clauses, payday loans, etc.

So CFPB essentially stuck its thumb in the eye of Congress in pushing forward with these measures.

Now Congress has struck back, saying, in effect (with its authority under the Congressional Review Act), "we don't like what this regulation does and this is our domain - therefore, we rescind it."

So, while one can try to say this is good versus evil, it is basically the legislature asserting itself on a matter of policy against a bureaucrat who it believes overstepped his proper role.

The result is to keep the status quo, nothing more. The rules in effect as a result of this action by Congress are the same ones that have governed arbitration clauses in every walk of life in American business for nearly a century.

For those who don't like it, that is fine. The ballot box is open as the prescribed means to effect a change. All this recent action amounts to is a declaration by Congress saying that this should not happen by bureaucratic edict. That may be bad policy, or it may be good policy, but it does uphold the rules of law favoring the electorally-accountable legislative branch over the authority of an unaccountable bureau chief.

11 comments

>For those who don't like it, that is fine. The ballot box is open as the prescribed means to effect a change.

Every single sentence you wrote here is extremely ignorant of the political reality in which that usual proper process has been in the muck for years. You're not realizing the effect that gerrymandering, voter suppression, and money in politics has on the ability of the usual system to work to reflect the desires of people, and that redirecting people to traverse that maze is essentially sending them on a quest to square a circle that will effectively keep the status quo.

And the status quo isn't good enough. Remember, just a few years ago, someone would be denied healthcare due to pre-existing conditions and die. THAT was the status quo, and it was so toxic that the party in power now, controlling all parts of the three branches could not repeal it. Forced arbitration is similar to healthcare, most people don't realize how bad it is until they have to go to head with it.

It occurs to me that many current issues can be abstracted as follows:

When corporations have become powerful monopolies (or regional monopolies) that trample on individual rights and captured regulators, should the citizens still respect the procedural correctness to its literal meaning? Or should we acknowledge that we have a flawed constitution, because while it checks the power of the government, the U.S. visionaries did not foresee the emergence of multinational corporations, structured in highly authoritarian ways, being able to influence public policy to great extent?

I believe we can agree that public goods are typically not as efficient as a _competitive_ private provider. But what if the market is not competitive at all? When ISPs/health insurers/hospital conglomerates essentially monopolizes different regions of the country, should the government step up and provide community broadband, single payer insurance or single provider healthcare? Or should we expect the government somehow being able to restore market competitiveness?

Remember, just a few years ago, someone would be denied healthcare due to pre-existing conditions and die.

This is an open and shut issue if the only thing you're worried about is the end consumer. The gov't, on the other hand, needs to worry about the system including the insurance companies. Changing the rules so that a person can forgo health insurance until they are sick is a sure fire way to start a death spiral.

It wasn't until the law was changed to include the individual mandate was the pre-existing condition clause even viable. I'd argue the individual mandate is so weak, that we might end up with a death spiral anyways.

What's the popular saying on HN? "Don't tear down the fence until you know why it was put up in the first place."

I’m sure the free market will find a way to provide healthcare without insurance companies, an all-but-required middleman.
What free market are you talking about?

Until we fix the collusion between the American Hospital Association[0] and insurance companies through the National Uniform Billing Committee[1] to opaquely set pricing, there will be no free market in the healthcare industry.

[0]https://en.wikipedia.org/wiki/American_Hospital_Association

[1]https://en.wikipedia.org/wiki/National_Uniform_Billing_Commi...

I mean that if the ban on denying coverage for pre-existing conditions causes the health insurance industry to collapse I'm sure the actual health care industry will figure something out.
Oddly, it already has, only it’s not for humans. Veterinarians are in a market that is considerably more free than doctors are, and insurance is not only not required, but rare by comparison.

Further, while the technology has advanced (eg cancer treatment for your dog), prices are much lower than what humans pay, and in some cases, declining.

The human health insurance market is quite different than the veterinary market, for some very obvious reasons.

Namely: - Inelasticity: economic terms, human healthcare is extremely inelastic, you'll spend everything you have to save your own life. Not so much with a pet. - Poor information: Because of so many middlemen, there is very little information for human healthcare, you rarely know how much something will cost before you owe it. - Non-Fungible: doctors are not a commodity that you can trade out like cereal. There are human relationships involved, that make it difficult to compare apples to apples.

These are all factors that human healthcare lacks that are generally necessary to make for an efficient market.

Agreed. The biggest issue I have with the parent comment is that the current Congress is unabashedly selectively enforcing the legality of these regulatory agencies, with a suspicious emphasis on helping corporations.
Unfortunately, this may not make the headlines nearly as much as the healthcare did.
This is a pretty one sided account. The CFPB didn't spring into existence because some unelected bureaucrat decided it should exist. The structure that the DC Circuit Court of Appeals found unconstitutional likewise wasn't the design of some unelected bureaucrat.

The Federal Arbitration Act is not the only piece of duly enacted legislation in question here. Another peice of legislation -- one that was passed by both Houses of Congress and signed by the President of the United States -- was the Dodd–Frank Wall Street Reform and Consumer Protection Act.

A lot of bankers and their lawyers fought against Dodd-Frank tooth and nail. They were very happy with how things worked up until that point, thank you very much. Normally the American public doesn't have the attention span to thwart the bankers' lobbyists -- they are in there 24/7 lobbying for narrow concentrated interests and public interests on the other side are too diffuse and abstract to mount an effective defense. But in this case the stars aligned and legislation was passed. So the lobbyists moved on from stopping the bill from being passed to killing it afterwords in the regulatory process.

Where were the impassioned speeches about separation of powers and the will of Congress when bank lobbyists were busy eviscerating the skin-in-the-game rule?

Sure, Congress has every right to pass a law, which is what they did here, and override a prior law. But by the same token the Dodd-Frank Congress had every right to override the Federal Arbitration Act. This isn't a question of separation of powers, it's a question of public policy. Congress didn't stand up for Congressional prerogatives, they stood up for banks.

A century ago, you and I would would hammer out the terms of a contract to our mutual and equitable interest and sign it. Both of us being bound.

Today, corporations want contractual "concepts" to only apply in one direction -- against the consumer. They expect to be able to strip away legal rights in their Terms of Service and End User Licensing Agreements, while also retaining the right to change ANYTHING at ANY time they please yet still have courts treat them like binding contracts.

What we need is a core set of consumer rights that are immutable.

> The problem with CFPB is that it sought to carve out its own view of what is right and proper for consumers of financial services without regard to the intent of Congress in having enacted the existing arbitration laws.

Dodd-Frank specifically required the CFPB to conduct a study on arbitration in financial agreements, and provided the CFPB authority to impose rules depending on the findings of that study. (12 U.S.C. § 5518, https://www.law.cornell.edu/uscode/text/12/5518)

This may be mostly correct, but the framing is nonsense.

Republicans, on issue after issue, don't give a shit about conforming to proper legislative processes. To pretend they have converted, on an issue that happens to benefit Wall St, and which all Democrats voted against, is willful blindness.

It's like saying there's something noble about an arsonist refusing to burn down the forest in his own backyard.

> The legislature passed the federal arbitration act almost 100 years ago. It was signed into law by the president. And it has been consistently upheld by the U.S. Supreme Court in the face of many and varied court challenges.

The Federal Arbitration Act was enacted to validate B2B arbitration agreements: before then, and also for a considerable time thereafter, many courts were hostile to arbitration agreements — because, it's thought, judges didn't want private arbitrators encroaching on the judges' turf [0]. Also, when the FAA was enacted, consumers and employees generally didn't enter into contracts. The "scope creep" of the FAA has been due largely to the Supreme Court's literal interpretation of the Act, giving it priority over all contrary state statutes and practically any other federal statute that doesn't expressly state otherwise.

[0] See, e.g., http://scholarship.law.missouri.edu/cgi/viewcontent.cgi?arti... (a somewhat-passionate review of the history that generally comports with my own understanding from roughly 25 years of occasional practice in this area).

Agreed. Unfortunately we find ourselves in an era of legislative stagnation. Obscure and popular policy alike have been unable to move through the legislative process for almost seven years. Compounding the problem is the rapid pace of change we live with. The legislature, unable to resolve many of the issues of the 20th century is building a heap of 21st century ones. And the growth rate of that heap is increasing, accelerating its increase in mass.

If history is any indicator, in political systems this broken, other institutions collect power and either that power is sustained and relieves legal pressure or that power is revoked and the pressure builds until the system comes apart.

> If history is any indicator, in political systems this broken, other institutions collect power and either that power is sustained and relieves legal pressure or that power is revoked and the pressure builds until the system comes apart.

Just curious if you can give a good Western example for similar things happening in history?

I found striking parallels between the United States and China's Tang Dynasty. The Tang Dynasty was the most prosperous and influential era of ancient China, in terms of both culture and military. It was marked with culture fusion and immigrants from across the sino-sphere settled in its capital. During the early times of this dynasty, a meritocratic higher education admission system was first instituted to provide an avenue for upward mobility. Life was prosperous and Tang people were fat.

All of that started falling apart after 200 years of reign, and the late stage of the empire was dysfunctionalized by highly partisan power struggles between two fractions (https://en.wikipedia.org/wiki/Niu–Li_factional_strife). The meritocracy also failed, as the rich could afford better education and examination preparation, and the examiners gave preference to the applicants from wealthy families. You can call it the Imperial Chinese Ivy League legacy. The power of the throne waned, and the emperors were stuck between or murdered by warlords and eunuchs.

Tang Dynasty lasted a total of 289 years. If the United States survives 2065, then it beats Tang’s record.

The late Roman Republic comes to mind. Problems regarding labor, citizenship and military service became significant after the third Punic War. The oligarchic Senate was opposed to really any major changes in these areas that would relieve the problems.

As things grew more dire a succssion of more and more radical populist leaders attempted to change the system from within by standing for election but most were assassinated.

Generals like Marius and Sulla began skirting the law to move the law ahead as they saw fit but leaving the system intact. Finally, Julius Caesar came along with a promise to fix everything but by destroying the republican system rather than by conforming to it. At this point it's no surprise that many Romans no longer cared.

> For those who don't like it, that is fine. The ballot box is open as the prescribed means to effect a change.

Actually, it's not the only way to effect a change. You can also spend millions on lobbying, smarty lawyering, slow but methodical creeping attack on consumer rights to effect change. In the 1940s, when the law was passed, arbitration agreements were not nearly as persuasive as they are today.

The companies enforcing these arbitration agreements aren't playing by the same rules everyone else is, they are changing the rules to their will, and then funding politicians to prevent and reversal.

> (its structure was declared unconstitutional by the D.C. court of appeals)

...which was promptly vacated by the full Circuit and is awaiting an en banc decision. Kavanaugh's opinion wasn't exactly a masterpiece of juris prudence, and there are ways for the full circuit (and scotus if necessary) to make a decision on the issues without touching the constitutional questions.

As another comment notes, the CFPB was required by law to study arbitration and encouraged to issue a rule in line with those findings. The arbitration rule was far from an overreach.

>For those who don't like it, that is fine. The ballot box is open as the prescribed means to effect a change.

Or for others to exploit those whose political protection only can guarantee very little actual security.

Such others who will now be even more emboldened, to levy attacks against those whose last line of defense now lies with words scribbled on a piece of paper… No prescription from the modern day effectively political skinner box needed.

> meaning, it is neither unjust, unfair

It's absolutely both of those.

> but it does uphold the rules of law favoring the electorally-accountable legislative branch over the authority of an unaccountable bureau chief.

Who gave the bureau chief the power?