The CFPB consent order that cited the $77 billion Navy FederalCredit Union Tuesday with deceptive debt collection practices israising questions about the world's largest cooperative and theCFPB's enforcement actions.

The Vienna, Va.-based credit union was ordered to pay affectedmembers $23 million and a $5.5 million civil penalty.

“I think that questions need to be asked about [Navy Federal's]incentive structure,” Keith Leggett, retired SVP and senioreconomist for the American Bankers Association, said. “What was theincentive structure? Were employees' compensation tied to debtcollection? And then you have to ask did this cause employees tooverstep and engage in unethical behaviors and was there somedirection by managers in the collection department?”