Clifford Chance

A Compliance Management System: What The CFPB Says You Need ….

29 November 2012

At the beginning of the month, the Consumer Financial Protection Bureau (CFPB) issued its first Supervisory Highlights, a report of the agency’s supervision over certain financial institutions (banks, saving associations, credit unions and their affiliates, as well as other companies that provide consumer financial products and services — collectively “Supervised Institutions”). Among other topics, the Supervisory Highlights outlines three public enforcement actions taken by the CFPB to correct certain illegal practices. The actions resulted in $435 million being paid in restitution to approximately 5.75 million consumers and civil money penalties of approximately $101.5 million. In each of the cases, the CFPB found that the offending companies lacked proper compliance programs and compliance oversight by senior management and the board.

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