2013-08-13cfpbjournal.com

``The CFPB estimates that, between July 8, 2011 and April 27, 2012, Castle & Cooke paid out more than 500 quarterly bonuses, ranging from $6,100 to $8,700, which totaled more than $4 million. The CFPB further claims that the company has paid out more than 1,100 illegal bonuses since April 2011, when the updated regulation went into effect.

Besides faulting Castle & Cooke for its quarterly bonus policy, the CFPB complaint also highlighted the lack of a paper trail documenting that policy. Regulation Z requires that evidence of compliance be kept on file for two years, and, according to the complaint, "while [Castle & Cooke] maintains payroll records of the quarterly bonus amounts paid to loan officers . . . it does not record what portion of a loan officer's quarterly bonus is attributable to a given loan;" nor do employee agreements "identify, explain, or refer to the existence of the Company's quarterly bonus program."''



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