This week, the CFPB issued a bulletin that outlined their expectations of lenders. In addition to that they will be answering exam questions based on this behavior.
It seems that if you are:
1. Self-policing
2. Self-reporting
3. Remediating without being told to do so.
4. Cooperating
Then, you stand a better chance of having an examiner that is agreeable to your company.
For instance, if you are self-policing then when an examiner identifies an issue, you should have already identified the issue. What??? is not a good response.
Self Reporting means that you are proactively reporting you errors, and demonstrating “fixes”.
Remediation means that when you do charge more to a consumer, you make financial restitution and document it.
Cooperation means that you are not playing games and address items honestly.
Failure to do this, will likely result in an examiner who is not too impressed with the way you run your business and the quality of service a consumer receives.
I must say that I’m concerned that the issues in the field must have been so profound, as to require that ethical conduct be examined and this bulletin to be issued. Your Thoughts?
