On June 25, the Consumer Financial Protection Bureau’s Office of Enforcement issued a bulletin outlining four factors that comprise what the Bureau calls “responsible business conduct,” and noting that these factors might favorably influence the Bureau when it exercises its enforcement jurisdiction. The Bulletin explains that the “purpose of this guidance is to encourage activity that has concrete and substantial benefits for consumers and contributes significantly to the success of the Bureau’s mission.” The four factors are as follows:
Self-policing: Proactive self-policing for “potential violations” of the consumer financial laws. The Bulletin explains that the Bureau might favorably consider any company-wide compliance management system, the relative robustness of this system, and whether there is a “culture of compliance” at the company that is the subject of an investigation.
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