I picked this up from the FTC who feeds FTC enforcement suggestions to the CFPB who feeds CFPB interpretation of the FTC suggestions to your state regulator. Its a daisy chain.
In an effort to curb inadequate compliance reporting, the FTC is introducing the following new model language that will be included in future FTC orders:
“Each compliance report shall contain sufficient information and documentation to enable the Commission to determine independently whether Respondents are in compliance with the Order. Conclusory statements that Respondents have complied with their obligations under the Order are insufficient. Respondents shall include in their reports, among other information or documentation that may be necessary to demonstrate compliance, a full description of the measures Respondents have implemented or plan to implement to ensure that they have complied or will comply with each paragraph of the Order; a description of all substantive contacts or negotiations for the divestitures and the identities of all parties contacted, and such supporting materials shall be retained and produced later if needed.”
The FTC explains that it intends this new language to clarify, not change, the requirements for compliance reporting. The CFPB, HUD, FNMA, USDA, FHLMC will all adopt this standard.
We will assist you when you have a finding requiring an action plan.
Thanks for reading.
Nelson A. Locke, Esq.