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Buckley Sandler C-Suite Financial Services Review: Building a Better Compliance Management System

Buckley Sandler C-Suite Financial Services Review

Clinton R. Rockwell, Andrew P. Pennacchia

The change in leadership and direction at the Consumer Financial Protection Bureau has prompted many providers of consumer financial services to question the importance of a rigorous, well-coordinated compliance management system. Changing emphasis and easing back — and saving some time and expense — is a particularly tempting option at a time when the CFPB leadership has attested that it will no longer “push the envelope” and aggressively assert its supervision and enforcement authority. But covered financial institutions have compelling reasons to maintain a steady focus on CMS, which can:

  • Prevent legal violations and consumer harm — both concerns of current CFPB leadership
  • Limit scrutiny by states, as enforcement moves in their direction
  • Prepare the institution for the inevitable swing of the pendulum back toward enforcement

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