CFPB's Vague New 'Responsible Conduct' Guidelines
Law360Jonice Gray Tucker
Jonice Gray Tucker and Valerie Hletko authored, "CFPB's Vague New 'Responsible Conduct' Guidelines," which appeared on Law360 on June 28, 2013.
On Tuesday, the Consumer Financial Protection Bureau issued CFPB Bulletin 2013-6, titled "Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation and Cooperation."
The bulletin identified four pillars of "responsible conduct" on the part of potential targets of enforcement action by the bureau — self-policing, self-reporting, remediation and cooperation. Such conduct may be rewarded with (1) resolution of an investigation with no public enforcement action; (2) treatment of subject conduct as a less severe type of violation; (3) reduction in the number of violations pursued; or (4) reduction in sanctions or penalties.