The Four D’s

Since the CFPB’s inception, enforcement actions have reportedly recouped $5.3 billion and levied more than Diane11$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”:

Debt Traps

  • Apparent short-term “solutions” to immediate needs aimed at people who may believe it’s their only option
  • Repeating and self-defeating repayment cycles

Dead Ends

  • Lack of responsiveness to consumer concerns and lack of consumer control over the process
  • Harassing debt collection tactics

Deceptive Marketing

  • 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 Dean

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