Since the CFPB’s inception, enforcement actions have reportedly recouped $5.3 billion and levied more than $200 million in civil money penalties. This includes actions on the new Servicing Rules, to illegal kickbacks under RESPA’s Section 8 and plenty of UDAAP in between. It seems like we’ve seen it all but as we know all to well there’s always something new to come.
It’s obvious the CFPB fully intends to live up to its billing as a “cop on the beat” (as Director Cordray has noted) and remains focused on attacking what it refers to as the “Four D’s”:
- Apparent short-term “solutions” to immediate needs aimed at people who may believe it’s their only option
- Repeating and self-defeating repayment cycles
- Lack of responsiveness to consumer concerns and lack of consumer control over the process
- Harassing debt collection tactics
- Giving inaccurate/false information or withholding key information
- Unlawful treatment based on a prohibited characteristic
- Lack of transparency for available options
Where do you stand with the “Four D’s”? Do your customers understand what they’re getting themselves into and what all their options are? Remember that the CFPB was created to focus on the risk to consumers, not banks. With the CFPB reportedly receiving over 20,000 consumer complaints in one month alone, do any of your products give cause for concern?
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!