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...

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Topics:  CFPB, Compliance, Enforcement Actions, Remediation, Responsible Business Conduct, Self-Policing, Self-Reporting

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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