A lot of the debate at today's Government Oversight hearing on the CFPB dealt with whether the CFPB was the most accountable or the least accountable federal government agency ever. My position has been that compared with other federal financial regulators, the CFPB is remarkably accountable. But accountability comes in many different ways and forms. I've tried to summarize comparative accountability visually in the chart below. It compares the oversight mechanisms that apply to the CFPB with some other agencies: the Environmental Protection Agency, the FDIC, the Federal Reserve Board, the FTC, the Office of Comptroller of the Currency and Office of Thrift Supervision, the SEC, and the Social Security Administration.
Now not all forms of oversight are equal. A GAO audit isn't the same as Presidential removal power, for example. Nonetheless, the chart (available as a better quality PDF
here) shows that the CFPB is subject to an extensive battery of oversight mechanisms--more than any of the other financial regulators included in the comparison.
At the very least, this chart provides pretty good evidence that claims that the CFPB is the least accountable agency ever just don't hold water, and that it is at least as accountable as the existing bank regulators.
Also, please note that the question of OCC and OTS removal power has not been resolved. There are some OLC opinion letters
that touch on the issue, but OLC has not opined on the matter directly and, in any case, the OLC's opinion is not the law. I would note that the National Bank Act of 1863 places restrictions on the ability of the Treasury Secretary to tell the Comptroller to take or refrain from action. The Treasury Secretary serves at the pleasure of the President, so if the President could simply remove the Comptroller, the restrictions on the Treasury Secretary's actions would be a nullity.
Let me emphasize that I'm not expert on all of these agencies, so I might have missed some points on the comparison chart. If so, please pipe in in the comments. Also, if you think there are other instructive comparison agencies, please say so and I'll revise.