[pktgen]

> 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)