By JeanIne catalano
we are entering a new era of consumer compliance, one that will require boards of directors to make increasingly difficult decisions and compliance officers to expand their role.
To arrive at a description of and suggest ways to address compliance in the future, this article will first
highlight the key evolutionary points in the history of consumer compliance, noting its bold start in the
late 1960s, followed by years of relentlessly expanded requirements and increasingly costly enforcement
actions. The purpose in highlighting these points will be to demonstrate how the path of consumer
compliance brought us to the present and where the path will take us going forward. This article will
demonstrate the expansion of consumer protection compliance, suggesting that the regulatory focus is
growing from lending disclosures and nondiscrimination in lending to “fair banking,” and that the pace of
enforcement actions will continue if not increase. Considering this trajectory, the article will then suggest
how consumer compliance will change going forward and how compliance officers can prepare for this
new world. Because transitioning to what will be a new world of compliance is not a job for compliance
officers alone, key messages for boards of directors are provided at the conclusion of the article.