CFPB Takes Steps to Prevent Consumer Harm

On 3/6/2020, the CFPB announced three steps to advance its strategy on one of its key priorities: preventing consumer harm. The three steps include:

  • Implementing an advisory opinion program to provide clear guidance to assist companies in better understanding their legal and regulatory obligations through advisory opinions;

  • Amending and reissuing its responsible business conduct bulletin, which articulates that the Bureau intends to provide credit to entities for their responsible conduct based on its extent and significance; and

  • Engaging with Congress to advance proposed legislation that would authorize the Bureau to award whistleblowers who report violations of Federal consumer financial law.

In conjunction with their announcement, the CFPB submitted proposed legislative language to U.S. House Speaker Nancy Pelosi and U.S. Senate President Michael Pence, as well as the Chairs and Ranking Members of the authorizing committees in both chambers. Among other things, the proposed legislation would amend the Dodd-Frank Act and provide authority to establish a whistleblower award program. According to the CFPB, the proposed incentive created for employees to report wrongdoing to the Bureau will assist in advancing enforcement cases, especially as it relates to fair lending violations. Under the proposed legislation, in cases where a whistleblower provides voluntary information that leads to a successful enforcement action, the Bureau will be able to pay an award based on a percentage of the monetary sanctions collected in the action.

The proposed legislative language can be found here

The CFPB release can be found here.

OFAC FAQ on COVID-19 Relief to Iran

OCC FAQs on Third Party Relationships