The situation you outline above is illegal under Dodd-Frank, the act that created the bureau.
Those who designed the agency were worried about precisely this kind of perverse incentive structure & required that it distribute all penalties back to consumers.
Those who designed the agency were worried about precisely this kind of perverse incentive structure & required that it distribute all penalties back to consumers.
https://www.consumerfinance.gov/about-us/payments-harmed-con...