The time has come to update the GCCA and to give it some teeth. As a separate entity, the corporation exists independent from the shareholders/owners and its employees. Except as otherwise provided by statute, rule or regulation applicable to a particular profession, all of the ultimate beneficial owners of the partnership interests in a partnership that renders one or more restricted professional services shall be licensed persons. There’s also the fact that unlike the SEC, FTC, Consumer Product Safety Commission, and most other government agencies with broad powers, the CFPB is not run by a commission.

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