Legal: To Self-Report or Not to Self-Report, That Is the Question

The Reverse Review

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On June 25, 2013, the CFPB issued Bulletin 2013-06, which discussed responsible conduct among financial services institutions. In the bulletin, the CFPB said it intends to consider a number of factors when determining whether or not to exercise its enforcement discretion, including:

  • The nature, extent and severity of the identified violations
  • Any actual or potential harm from the violations
  • Whether there is a history of past violations on the part of the financial services company
  • The financial services company’s effectiveness in addressing violations

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