Thanks, Wells Fargo, you shouldn’t have

We can all thank Wells Fargo for an unexpected compliance gift this year. Thanks to some questionable incentive practices on their part, the CFPB has issued a Bulletin describing in great detail, their expectations for managing an appropriate incentive program. Thanks, Wells Fargo. Sorry we didn’t get you anything in return.

Like many Christmas gifts, this one comes with instructions. I know many of us like to “wing it” when it comes to those pesky instructions, but this is one gift that will require us to pay attention.

The bulletin is very clear that all aspects of the controls that should be in place for an incentive program originate within the Compliance Management System (CMS). (Are you sensing a theme here?  Whenever a new regulatory issuance has come out recently, the first thing it says is that it all ties back to the financial institution’s CMS.)

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