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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Topics:  CFPB, Responsible Business Conduct

Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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