The latest action against an auto lender underscores the CFPB's expectation that lenders will affirmatively act to protect customers throughout and after the consumption of the transaction.

In the instant case the CFPB fined a lender nearly $3 million as a result of flaws with its automated credit reporting system that was providing inaccurate information to credit bureaus regarding the balances, dates of delinquencies and number of delinquencies.

Although the inaccurate reports were the result of a problem with a computer vendor, the lender did nothing other than report the problem, while continuing to use the flawed system.

As a result the CFPB found the lender violated Dodd-Frank by misrepresenting to consumers that they would make accurate reports to credit bureaus.

This case clearly illustrates the point that if consumers are being harmed by something over which the lender has direct or is direct control, the lender has an affirmative obligation to prevent the harm.

Otherwise, lenders can be subjected to substantial fines and penalties by the CFPB for failing to act.