14
Aug
In addition to spotlighting the critical importance of a CMS, the CPFB’s citing of CMS-related deficiencies begs the question of whether anyone is capable of meeting the CFPB’s expectations.
The CFPB has generated acute awareness of the term “compliance management system” (CMS) through its highly publicized consent orders. Since it began issuing orders in 2011, the CFPB has invariably cited “significant weaknesses” in the subject party’s CMS along with violations of specific federal consumer financial laws. In addition to spotlighting...