Justice Muse

Wells Fargo seems to be in the hot seat again with regulators. Repeated regulatory action like this in any industry should signal that there is a lack of an effective comprehensive compliance program. The key word here is effective. Every financial institution has a written compliance program. But, this should serve as a cautionary tale about identifying consistent themes about the effectiveness of one's processes and procedures.

These are interesting developments in the CFPB rulemaking space. The proposed rule will undoubtedly have serious implications on financial institutions. Banks will need to consider how to further safeguard the information shared and how to ensure the accuracy of that data. This rule will expose banks and other financial institutions to a fair amount of risk and it will be interesting to see how these institutions negate and navigate that risk.