CFPB “Responsible Conduct” Guidance

The Consumer Financial Protection Bureau issued guidance yesterday on how banks and other financial providers under its jurisdiction can show they are responsible from a "Self-Policing, Self-Reporting, Remediation, and Cooperation" standpoint and hopefully influence discretionary enforcement functions favorably.

“there are activities they can engage in both before and after the conduct in question has occurred that the Bureau may favorably consider in exercising its enforcement discretion. Specifically, a party may proactively self-police for potential violations, promptly self-report to the Bureau when it identifies potential violations, quickly and completely remediate the harm resulting from violations, and affirmatively cooperate with any Bureau investigation above and beyond what is required.”

The CFPB’s announcement is here and the guidance itself can be read here.