Financial Institution Sales Practices and Incentive Compensation Arrangements in the Wake of Wells Fargo: What Can We Expect from the Consumer Financial Protection Bureau? (MLC575L)

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  60 minutes
  
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Tools and Techniques to Develop Sales Practices and Incentive Compensation that Minimize Regulatory Risk and Avoid UDAAP Violations

In November 2016, the Consumer Financial Protection Bureau (CFPB) issued a compliance bulletin that addresses detecting and preventing consumer harm from incentive compensation arrangements. Prompted by Wells Fargo Bank’s alleged improper incentive compensation arrangements, the CFPB’s bulletin makes clear that while properly implemented and reasonable incentives can benefit companies, employers and the financial market overall, “incentive programs can pose risks to consumers, especially when they create an unrealistic culture of high-pressure targets.” Financial institutions need to be aware of the CFPB’s new directives to ensure that their incentive compensation programs, both for employees and third-party service providers, comply with laws regarding unfair, deceptive and abusive (UDAAP) acts and practices.

In this session, expert speaker Chrys D. Lemon will provide you with tools and techniques to develop sales practices and incentive compensation arrangements that are designed to minimize regulatory risk. Chrys will talk about how an incentive compensation program can create UDAAP problems if it is not properly structured, and he’ll help you learn how to ensure that your company does not become the next target of the CFPB’s enforcement efforts in this hot compliance area.

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Chrys Lemon is a partner in McIntyre & Lemon, PLLC, in Washington, D.C. He specializes in financial services law, particularly related to marketing of consumer financial products and services, privacy law, insurance law, and regulation of financial institutions by the Consumer Financial Protecti... More info

 


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