CFPB's Vague New 'Responsible Conduct' Guidelines

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On Tuesday, the Consumer Financial Protection Bureau issued CFPB Bulletin 2013-6, titled "Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation and Cooperation."

The bulletin identified four pillars of "responsible conduct" on the part of potential targets of enforcement action by the bureau — self-policing, self-reporting, remediation and cooperation. Such conduct may be rewarded with (1) resolution of an investigation with no public enforcement action; (2) treatment of subject conduct as a less severe type of violation; (3) reduction in the number of violations pursued; or (4) reduction in sanctions or penalties.

Originally Published in Law360 New York - June 28, 2013.

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