The Consumer Financial Protection Bureau (CFPB) is an independent agency of the United States government responsible for consumer protection in the financial sector (Wikipedia). The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) promulgated by the Congress established the CFPB. They work to give consumers the information they need to understand the terms of their agreements with financial companies. They work to make regulations and guidance as clear and streamlined as possible so providers of consumer financial products and services can follow the rules on their own.
The main functions of the CFPB is to protect consumers by carrying out federal consumer financial laws. Among other things, they:
•Write rules, supervise companies, and enforce federal consumer financial protection laws
•Restrict unfair, deceptive, or abusive acts or practices
•Take consumer complaints
•Promote financial education
•Research consumer behaviour
•Monitor financial markets for new risks to consumers
•Enforce laws that outlaw discrimination and other unfair treatment in consumer finance (CFPB website)
On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the following four broad categories of conduct that the CFPB “may favourably consider” i.e that may make the CFPB to look favourably upon Organisations:
• Self-policing: The entity’s investment in a “robust compliance system” that “facilitate[s] early detection of potential violations,” including how the conduct was detected, procedures in place to prevent, identify or limit the identified wrongful conduct, whether executives and others high up in the chain of command knew of or participated in that conduct, and whether there were any deficiencies in compliance procedures more generally.
• Self-reporting: The entity’s “prompt and complete” reporting to the CFPB and other regulators as well as to impacted consumers of all violations or even potential violations.
• Remediation: The entity’s efforts to provide “full redress” for impacted consumers, implement procedures to prevent recurrence, and change future conduct. The CFPB will consider how long it took the entity to stop the offending conduct and begin remediation after the conduct was identified, whether there were any consequences for responsible individuals, whether the remediation addressed all monetary and non-monetary harm to impacted consumers, and whether there were any improvements to policies and procedures.
• Cooperation: The entity’s interactions with the CFPB once the CFPB becomes aware of a potential violation must go “above and beyond what the law requires” to receive credit. The CFPB will consider whether the entity undertook a thorough review of the misconduct, promptly made the results of that review available to the CFPB, created a “complete and thorough written report detailing the findings of its review,” and voluntarily disclosed of material information not requested by the CFPB. (www.lexology.com)
The world as we know it today is a global village and International Business rules of best practice are as the term states ‘International’, rules established for good conduct in any business environment, can be termed to be universal, which only need to be domiciled in any other country, by the Government of that country, to make it law. International Corporate Organisations (Multi-nationals) can learn from this four categorised actions of good conduct in other not to run foul of the enforcement agencies, especially in terms of corporate responsibility issues.