The CFPB is reorganizing its headquarters staff for supervision so it will no longer be divided into separate offices for nonbank and large bank supervision.  While there will continue to be two offices, one office will now be focused on exams and the other will be focused on policy. 

The exam office will oversee the CFPB’s efforts to: “recruit, train, and commission examiners; ensure policies and procedures are followed; and plan and execute examinations appropriately in light of [the CFPB’s]  resources and priorities.”  Paul Sanford will serve as the office’s Acting Assistant Director and four regional offices will report to the headquarters office. 

The policy office “will ensure that policy decisions for supervision are consistent with both the law and [the CFPB’s] mission, and that they are consistent across markets, charters, and regions.”  The office will be organized by product or service market rather than by the type of financial institution, with the strategies and policies it develops to apply to banks and nonbanks. Peggy Twohig will serve as the office’s  Assistant Director. 

While time will tell, our initial impression is that the reorganization could represent an improvement to the extent it fosters equal treatment of banks and nonbanks.