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Volume 25 - Number 2

January 20, 2014

Handling Consumer Confusion Requires Sophisticated Triage

The CFPB’s emphasis on consumer complaints has injected a whole new compliance dynamic for lenders of all types and sizes. And in order to successfully manage what is likely the most problematic complaint – confusion – lenders are going to need a more sophisticated triage process. “In an environment in which regulators cite customer confusion as a primary rationale for actions on everything from advertising and sales practices to rewards programs to arbitration clauses, establishing a high threshold for a matter to qualify as a...

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