This blog shares actions proven to prepare for regulatory exams by adopting a proactive and informed approach. At a high level, to prepare for regulatory examinations, organizations should adopt a proactive and informed approach. Staying abreast of regulatory changes and updates is crucial, and the bank should establish a robust Compliance Management System (CMS) that encompasses policies, procedures and controls aligned with current regulatory requirements. Regular internal audits and risk assessments must be conducted to identify and rectify compliance gaps, with a commitment to promptly address any deficiencies discovered.
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The Consumer Financial Protection Bureau (“CFPB”) filed an opposition brief (the “Opposition”) on March 12, 2024 in response to a request by plaintiff trade groups to enjoin the CFPB’s final credit card late fee rule (the “Final Rule”) during the pendency of a lawsuit seeking to invalidate the Final Rule. In the Opposition, the CFPB argues that plaintiffs are unlikely to succeed on the merits, and that the Final Rule is consistent with the CARD Act’s mandate that late fees be “reasonable and proportional” to the late payment. Plaintiff’s reply brief (the “Reply”) in support of its motion for a preliminary injunction (the “Motion”) was filed on Thursday, so the Motion is now fully briefed.
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Today’s current economic climate is already influencing consumer spending and credit in 2024, and is becoming a hot topic for businesses seeking to engage past-due customers.
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