Compliance programs and being able to defend actions being taken will continue to be as important as before, and in ways not as obvious. For example, the UDAAP provisions of Dodd-Frank that gave Richard Corday broad leeway, empower state AG’s as well. There are at least 17 AGs who are likely candidates for using that power. Even during the Corday era, there were notable enforcement matters from states in team-ups or under Dodd-Frank on their own. For those reasons alone, and many more, individual products or activity-based compliance programs will be critical enterprise-wide.
During the webinar, Ms. Megaris emphasized, "What that means is being able to demonstrate compliant activity, avoiding investigations, and nuanced legal arguments will be as important as or more important than ever."
Mr. Pompan touched on the unfinished business that could be supported by modernizing the rules.
What happens next, and the impact that will have on consumer financial service providers, nobody really knows, but for now it should mean business as usual for any compliance practice.