Legal: To Self-Report or Not to Self-Report, That Is the Question 

On June 25, 2013, the CFPB issued Bulletin 2013-06, which discussed responsible conduct among financial services institutions. In the bulletin, the CFPB said it intends to consider a number of factors when determining whether or not to exercise its enforcement discretion, including: -The nature, extent and severity of the identified violations -Any actual or potential harm from the violations -Whether there is a history of past violations on the part of the financial services company -The financial services company’s effectiveness in addressing violations Notwithstanding these four factors, the bulletin suggests that a financial services company that proactively self-polices for potential