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Abstract: 

In this article, the authors report that the CFPB has devoted significant resources to reviewing the compliance management systems (“CMS”) of financial institutions, and has noted that a robust and effective system is a critical component of a well-run financial institution. After discussing the statutory background of CFPB enforcement, the authors set out the characteristics and benefits of a strong CMS program.

Keywords: Unfair, Deceptive, or Abusive Acts or Practices (“UDAAP”); Compliance Management System (“CMS”)

Affiliations:  1: Goodwin Procter, LLP; 2: Goodwin Procter.