CFPB Exams

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As we wrote last week, the CFPB recently published a Fall 2015 Supervisory Highlights which included a summary of changes that have been made to the CFPB’s supervisory appeals process. The original supervisory appeal process was published three years ago in CFPB Bulletin 2012-07. The revised supervisory appeals process incorporates a number of changes.… Continue Reading

In its Fall 2015 Supervisory Highlights, which covers supervision work generally completed between May and August 2015, the CFPB highlights legal violations resolved using non-public supervisory actions involving consumer reporting, debt collection, student loan servicing, and mortgage origination and servicing.  The report includes a discussion of targeted ECOA reviews and an announcement that the CFPB has revised its supervisory appeal process.… Continue Reading

Yesterday, the following four CFPB-related bills were passed by the House Financial Services Committee:

  • H.R. 3192, the “Homebuyers Assistance Act”: The bill would provide a hold harmless period for the TILA/RESPA Integrated Disclosure (TRID) rule that is scheduled to go into effect on October 3, 2015.  Although the CFPB recently delayed the effective date of the TRID rule until such date, it declined to adopt a formal hold harmless period, despite industry calls for such a period. 
… Continue Reading

In its Summer 2015 Supervisory Highlights, which covers supervision work generally completed between January and April 2015, the CFPB highlights legal violations resolved using non-public supervisory actions involving consumer reporting, debt collection, student loan servicing, mortgage origination and servicing, and fair lending.  The report indicates that recent supervisory resolutions in the areas of  mortgage origination,  fair lending, mortgage servicing, deposits, payday lending and debt collection have resulted in remediation of approximately $11.6 million to more than 80,000 consumers.… Continue Reading

The Offices of Inspector General for the Fed/CFPB, FDIC, Treasury and NCUA have issued a report setting forth the results of their review of the extent to which the CFPB and prudential regulators (FDIC, Fed, OCC and NCUA) were coordinating their supervisory activities and avoiding duplication of regulatory oversight responsibilities.

To assess the agencies’ efforts, the steps taken by the OIGs included reviewing relevant provisions of the Dodd-Frank Act, interviewing CFPB and prudential regulator officials, reviewing MOUs developed by the CFPB and prudential regulators, and conducting research to determine if there were complaints from regulators or financial institutions regarding regulatory overlap. … Continue Reading

Key members of the CFPB’s enforcement, regulatory and supervision offices spoke yesterday at PLI’s 20th Annual Consumer Financial Services Institute in Chicago. As was the case during the New York City version which took place on April 6, the session addressed recent developments and upcoming initiatives at the CFPB, and took the form of a Q&A between the moderator and a panel of practitioners and CFPB personnel.… Continue Reading

Key members of the CFPB’s enforcement, regulatory and supervision offices spoke yesterday at PLI’s 20th Annual Consumer Financial Services Institute in New York City.  The session addressed recent developments and upcoming initiatives at the CFPB, and took the form of a Q&A between the moderator and a panel of practitioners and CFPB personnel.… Continue Reading

The CFPB has revised the chapters of its Supervision and Examination Manual specific to TILA and RESPA, incorporating the TILA/RESPA integrated disclosures (TRID) requirements that are set to take effect on August 1, 2015.  These chapters replace versions of the TILA and RESPA procedures released on November 27, 2013.

As is the case for most statute-specific portions of the Manual, the TILA and RESPA chapters each contain two parts:  a narrative portion outlining the substantive requirements and restrictions of the law and its implementing regulation, and a detailed examination checklist. … Continue Reading

As he has done in prior years, Director Cordray spoke earlier this week to the National Association of Attorneys General.  His prepared remarks focused on the familiar theme of “the four Ds” that create obstacles for consumers in the financial services marketplace–deceptive marketing, debt traps, dead ends, and discrimination.

Director Cordray’s remarks included the following noteworthy comments on the “Four Ds”:

  • Deceptive marketing:  Director Cordray stated that “one of the most objectionable experiences we have had to date has been with law firms that purport to be helping people resolve their debts, but really are misusing their law license to defraud consumers.” 
… Continue Reading

In his prepared remarks for an appearance last week at the Exchequer Club, CFPB Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision.  (The Exchequer Club’s members include senior professionals from trade associations, federal regulatory agencies, law firms, congressional committees and national press.)

Mr. Antonakes commented on why “the traditional approach to supervision wouldn’t work at the Bureau.” … Continue Reading