Preparing for the Firestorm of a CFPB Settlement Announcement


A specialty professional services firm had been under lengthy investigation by the Consumer Financial Protection Bureau (CFPB). Its leadership knew that once an announcement was made – regardless of whether it was a settlement or a lawsuit – the firm would be subject to intense media scrutiny and needed to prepare to communicate directly with its customers, employees, vendors and other audiences critical to its business.


The client turned to Hillenby because of our in-the-trenches experience with the CFPB. We took into account a variety of factors that would impact perception of the client and the settlement – including potential outcomes, audiences and messages – and developed a comprehensive strategic plan. In addition to coordinating with the internal team, we worked closely and directly with outside counsel to ensure that the positioning and strategy complemented the legal effort.

Elements of the strategic plan included:

Working Group: We established with the client a small working group that had broad knowledge of the specific issues the CFPB was likely to raise and could provide swift feedback and approval both during the planning process and when the announcement was made. Such a group helps streamline the communications process in a situation in which minutes can make the difference between statements going unchallenged or being properly responded to in media stories.

Message Development:  Hillenby built a foundation for all of our materials by creating a master key messages document. It included both the broad themes we wanted to emphasize, as well as messages on specific topics we knew would be raised as part of the settlement. It was critical for this document to be comprehensive and applicable to all audiences to make the development of all future, more specialized documents as efficient as possible.

Materials Creation: Using the agreed-upon messaging, we created a full suite of materials, including a press release and dedicated talking points and emails for each target audience. Each of these materials was approved in advance, to the extent possible, with the understanding that the Working Group could make spot changes as needed to reflect the announcement.

“Tick-Tock” Document: Because of the number of audiences that needed to be informed of the CFPB announcement in a tight timeframe, we created a detailed minute-by-minute document that captured explicit tasks and responsibilities to ensure a coordinated and thorough effort to share the client’s messages.

Rapid Media Response: Responding promptly to media inquiries is critical in this situation, as most news outlets want to post something quickly following the announcement. To prepare, Hillenby compiled a media list in advance that encompassed national CFPB reporters, relevant trade publications and local outlets. We then established a system with the client in which we fielded all media inquiries and managed the response process. We worked to push out our release proactively to key outlets, and we followed up aggressively with any outlets that didn’t include the client’s messages or contained misinformation.  


The client received a large share of voice in the news stories that ran, and the message was roundly seen as highly compelling by critical business decision-makers. Several industry publications that we worked with proactively ran the client’s press release in full, which is unusual. The client received about 20 percent less coverage than a competitor of similar size and reach that had recently been part of a CFPB announcement.


"I'm happy." - Managing partner of the firm
“Really nice job on the public relations and talking points.” – President of a large industry trade publication