The Consumer Financial Protection Bureau’s Whistleblower Program: How It Works and What It Means for Financial Services Companies


On December 15, 2011, the Consumer Financial Protection Bureau (Bureau or CFPB) issued a bulletin announcing its program to collect whistleblower information and law enforcement tips, stating that it “welcomes information from current or former employees of potential violators, contractors, vendors, and competitor companies.” Through an active outreach campaign, including press releases and public pronouncements, the Bureau has made it clear that obtaining information from whistleblowers will be a central component of its enforcement efforts. Indeed, in the press release accompanying the bulletin, Richard Cordray, current Director of the Bureau and then-Assistant Director of Enforcement, stated: “We are providing whistleblowers and other knowledgeable sources with a direct line of communication to the CFPB….Their tips will help inform Bureau strategy, investigations, and enforcement. And they will help us fulfill our commitment to consumers.” Whistleblower protections are not new, and the CFPB’s protection joins several other governmental whistleblower programs from the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Internal Revenue Service (IRS), and Department of Justice (DOJ). Confronted with a new, expansive class of potential whistleblowers, financial institutions need to understand how the Bureau’s whistleblower protections work and develop best practices to reduce the risk of incurring penalties—reputational and monetary—resulting from whistleblower actions.

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