Over 80% of Chief Risk Officers surveyed last year identified Consumer Compliance as an area of emerging risk and regulatory focus. A year later, that view has proven prescient. In this publication, we discuss the challenges facing Compliance officers under the regulatory environment, identify the priority themes worth their attention, and recommend actions.

Key regulators have sent unmistakable, coordinated signals that elevated scrutiny on consumer compliance is forthcoming. As this evolution unfolds, there remains substantial ambiguity around what the expectations are especially related to areas like fair lending and fee revenue practices. To help institutions structure their efforts, we highlight four complementary priorities.

In the absence of obvious safe harbors, institutions proactively ought to conduct structured self-assessments around these priorities against articulated institutional values and consumer principles, then use findings to drive change in business practice or provide redress to consumers where necessary. Acquisition of new capabilities in analytics and change management will also be valuable. Those that prepare vigilantly will be better anchored to shape the discourse as evolution in regulatory expectations play out. Institutions that are slow to react may miss out on the opportunity to build goodwill and find themselves at a disadvantage when unforgiving scrutiny eventually arrives.

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