Comparing Regulator-Driven and Self-Remediation Programs

This document is a guide that compares and contrasts regulator-driven remediation programs with self-remediation programs undertaken by financial institutions. It outlines the key differences in timelines, funds and tax reporting, check-cashing rates, handling of uncashed funds, and third-party involvement. Financial institutions often have more flexibility with self-remediation, allowing them to set their own timelines and processes. In contrast, regulator-driven remediations typically follow structured timelines as outlined in consent orders. The guide details the requirements for establishing Qualified Settlement Funds (QSF) in regulator-driven remediations, which differ from self-remediation processes. Additionally, it discusses the expectations regarding check-cashing rates and the handling of uncashed payments, emphasizing the need for compliance with regulatory requirements. The document also highlights the potential involvement of third parties in both types of remediation, noting the distinct roles and responsibilities that may be required by regulators.