Interesting Insights from the Summer 2021 CFPB Supervisory Highlights
Most creditors find 100 percent regulatory compliance to be an elusive goal, and auto-secured creditors are no exception. My clients often say to me, “Gee, I would have fixed that compliance gap if I had only known it was there!” Are examiners sympathetic to this response? Or do they give the creditor an icy stare and say, “Well, your compliance management system is supposed to uncover those gaps”? An even worse compliance strategy is waiting for your customers to complain. S