[Sean Cash]

Sean's correct, the CFPB has no authority to regulate business lending and I highly doubt that it would be granted any additional authority to regulate the industry. If new legislation was crafted to cover alternative lending, I would suspect it would provide bank regulators oversight responsibility. I think the argument would be that alternative lenders have become "systematically important" to the overall financial system and therefore should be under the purview of those agencies responsibility for the economy overall.

However, any legislation is years away (if ever). I think Ms. Mill's paper simply signifies the beginning of what will be a flood of academic and governmental research trying to ascertain the size and impact of alternative lending. We as an industry need to be aware of and hopefully contribute to the overall conclusions of this research as it will be these conclusions that dictate the form of any future legislation.

Basically, we need to be involved in and help shape the debate.

At Lend360, a conference coming up in October that I'm participating in organizing, there will be a lot of discussion dedicated to best practices, collective self-regulating, and lobbying. Also plenty of technology showcasing and other valuable experiences. If anyone is interested in best practices or starting an early movement towards collaborating collectively, I suggest you sign up and go!