On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the following four broad categories of conduct that the CFPB “may favorably consider”:

• Self-policing: The entity’s investment in a “robust compliance system” that “facilitate[s] early detection of potential violations,” including how the conduct was detected, procedures in place to prevent, identify or limit the identified wrongful conduct, whether executives and others high up in the chain of command knew of or participated in that conduct, and whether there were any deficiencies in compliance procedures more generally...