Yet Mulvaney and his deputies provided little feedback or direction on the proposals, according to former Silberman staff members I spoke with. “It was radio silence from them on what direction they wanted to take,” the former staff member told me. The process stalled. Payday lenders, who had expected quick action from Mulvaney, began to panic. Cordray’s ability-to-repay rule would go into full effect in August 2019, in a little more than a year. Mulvaney’s team might come up with a new rule before August, but it might not, and in the meantime payday lenders would have no choice but to reconfigure their businesses — or shut them down — to prepare for the old one. Shaul, the leader of the Community Financial Services Association, told me that he had difficulty getting any sense of where the bureau was headed. “I was not able to get to see Mulvaney,” Shaul told me. “I was hoping we could convince Mulvaney to repeal that rule and craft a new rule.” What they needed was certainty, or at minimum some kind of delay. As months passed without any word, Shaul told me, his members were increasingly set on suing the agency.

What happened next underscores some of the absurdity and complexity of turning an agency inside out. In early April, Johnson granted Shaul an introductory meeting at the agency’s headquarters. At the last second, Shaul emailed to say he would be bringing Chris Vergonis, one of the association’s lawyers at Jones Day — and one of the people who would prepare any lawsuit against the agency. His presence was potentially dangerous for Mulvaney’s team; it could raise questions about whether the bureau was improperly coordinating with the industry. According to notes of the meeting, taken by a career bureau employee and obtained by the consumer group Public Citizen, Shaul told Johnson that the association had in fact been preparing to sue the C.F.P.B. to stop Cordray’s rule but now believed that it would be better to work with the bureau to write a new one. With the Cordray rule looming, Shaul stressed, they would need to move quickly.

A person familiar with the meeting, who asked for anonymity because of the legal sensitivities involved, told me that Shaul and Vergonis kept pushing for details of the new rule and at one point asked outright what reaction the bureau would have to a lawsuit. According to the staff notes, Johnson replied carefully, as a good lawyer would; it would be inappropriate for him to discuss either the rule or the lawsuit, he told them. Shaul gave me a similar account. “I found them so cautious as to preclude our having any real discussion,” he told me. “We came away from the meeting thinking that we were not going to get many answers.” Four days later, the Community Financial Services Association and another industry group filed suit against the bureau.

The C.F.P.B.’s response was atypical of a regulatory agency. In mid-May, the bureau’s lawyers called Vergonis with a proposal: They now wanted to in effect join forces with the industry, by asking a judge to stay both the compliance date of Cordray’s rule and the lawsuit. In a kind of regulatory jujitsu, the bureau would cite Mulvaney’s own decision to reconsider the Cordray rule as an excuse to stop the clock on the August 2019 implementation. There was just too much fog. “The bureau’s decision to initiate rule making to reconsider the payday rule creates inherent uncertainty,” the bureau lawyers and Vergonis’s team wrote in court papers filed later that month. “There is no way to know whether plaintiffs’ members will ultimately need to comply with the payday rule, a modified payday rule or no rule at all.”

The bureau still had not explained what kind of rule it planned to propose, much less implement, and in June, a Texas judge rejected the request for a stay of the compliance date. But that October, the C.F.P.B. announced that its new rule would indeed target the ability-to-repay requirement. Not long after, the judge agreed to grant the stay, in effect delaying the core of Cordray’s old rule. Inside the bureau, according to two former employees and an industry lawyer I spoke with, the regulation-writing team lurched into high gear, rushing to deliver what the bureau had promised. The industry had won what it needed most: time.