A Case Study in Practical Approaches to Self-Cures in the Context of CFPB Examinations
Financial Services attorney Leonard Bernstein and consumer protection attorneys Da'Morus Cohen and Anthony DiResta co-authored an article for the American Bar Association's Business Law Today about the project that Holland & Knight’s Consumer Protection Defense and Compliance Team and NERA Economic Consulting’s Antitrust and Competition Practice recently completed together. The project consisted of a financial institution implementing a self-cure resulting from an inadvertent coding issue that affected the frequency of the financial institution’s review of consumers’ interest rates for certain credit products. The attorneys break down questions encountered in the course of the case and how they were addressed.
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