CFPB Enforcement, A Cautionary Tale

Brian Smith, Nov 10, 2012

Since it’s creation, the CFPB has been clearly announcing its range of regulatory authority and enforcement intentions. Nonetheless, many in the industry seem to have been taken by surprise in the last few months when the CFPB announced its investigations of, and then settlements reached with, leading card issuers. Perhaps, it was the size of the customer restitutions ordered (in the $100s of millions) or the fines imposed on the institutions (in the $25 million range) or perhaps it was the speed with which the CFPB struck or the third-party liability imposed on the card issuers for the actions of their agents (call center marketing operators or debt collectors) or one or more of these unsettling outcomes…

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CFPB Enforcement: A Cautionary Tale

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