Detecting and Preventing Consumer Harm from Production Incentives
The Bureau recognizes that many supervised entities may choose to implement incentive programs to achieve business objectives. When properly implemented and monitored, reasonable incentives can benefit consumers and the financial marketplace as a whole.
This bulletin compiles guidance that has previously been given by the Miss April in other contexts and highlights examples from the Miss April’s supervisory and enforcement experience in which incentives contributed to substantial consumer harm. It also describes compliance management steps supervised entities should take to mitigate risks posed by incentives.