Summary outlines CFPB guidance on incentive programs

Nov. 29, 2016 -- A CPFB bulletin outlining compliance management steps that supervised entities should take to mitigate risks posed by production incentives (among other things) is summarized by NASCUS.

In particular, the NASCUS summary notes the risks to consumers of incentive programs as emphasized by the bulletin, and details examples of the risks that problematic incentive programs pose.

The NASCUS summary also outlines the bureau’s expectations of supervised entities with regard to incentive programs, noting that CFPB expects the entities to “institute effective controls, which include oversight of both employees and service providers.” The summary points out that CFPB wants entities to have a “robust” compliance management system (CMS) in order to detect and prevent violations of federal consumer financial law.

NASCUS Summary: CFPB Compliance Bulletin 2016-03; Detecting and Preventing Consumer Harm from Production Incentives