Tilling Lee

May 15, 2023 | businesslawtoday.org | Leonard Bernstein |Da'Morus Cohen |Anthony DiResta |Tilling Lee

In Consumer Financial Protection Bureau (“CFPB”) examinations, an assessment factor in the CFPB’s implementation of the Federal Financial Institutions Examination Council’s (“FFIEC”) Uniform Consumer Compliance Rating System (“CC Rating System”) is “self-identification of consumer compliance issues and corrective action undertaken as such issues are identified” (“self-cures”).[1] The CFPB Supervision and Examination Manual states: These statements raise practical questions about how to...