CFPB Supervision

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The CFPB has announced that it will begin examining post-secondary schools, such as for-profit colleges, that extend private loans directly to students and/or parents to fund undergraduate, graduate, and other forms of postsecondary education.  The announcement was accompanied by the CFPB’s issuance of an update to its Education Loan Examination Procedures manual.  The update…

The CFPB has released the Fall 2021 edition of its Supervisory Highlights.  The report discusses the Bureau’s examinations in the areas of credit card account management, debt collection, deposits, fair lending, mortgage servicing, payday lending, prepaid accounts, and remittances that were completed between January 2021 and June 2021.  Accordingly, the majority of examinations discussed…

Last week, in advance of Director Chopra’s appearances before the House Financial Services Committee and the Senate Banking Committee, the CFPB issued its Spring 2021 Semi-Annual Report to Congress covering the period October 1, 2020 through March 31, 2021.

With former Director Kraninger having resigned on January 20, 2021, the report primarily reflects CFPB…

The CFPB has added a new section to its Supervision and Examination Manual titled “Compliance Management Review-Information Technology.”  The new section supplements the existing section on Compliance Management Review to provide examination procedures to be used by CFPB examiners to assess information technology (IT) and IT controls as part of a Compliance Management System (CMS)…

We look at the practices found to be unlawful by CFPB examiners in these markets, discuss what the findings signal for future scrutiny of these markets by the “new CFPB”, and share practical takeaways for companies operating in these markets.  Issues highlighted in our conversation include the CFPB’s findings regarding “unreliable furnishers,” furnisher handling of…

We look at the practices found to be unlawful by CFPB examiners.  In addition to “as low as” rate advertising by providers of private student loans that did not disclose rates were dependent on borrower creditworthiness, we discuss servicer practices involving: providing inaccurate information about eligibility for the Public Service Loan Forgiveness program, automatic placement…

We discuss the practices found to be unlawful by CFPB examiners in the areas of deposits, auto servicing, and payday lending, identify practical takeaways for avoiding criticism by the “new CFPB,” and share our thoughts on what the findings signal for future scrutiny in these areas by the “new CFPB.”

Ballard Spahr Senior Counsel Alan…

The CFPB has released the Summer 2021 edition of its Supervisory Highlights.  The report, which contains 48 pages of supervisory observations, discusses the Bureau’s examinations in the areas of auto servicing, consumer reporting, debt collection, deposits, fair lending, mortgage origination and servicing, private student loans, payday lending, and student loan servicing that were completed…

In addition to rescinding seven policy statements providing flexibility to companies in meeting certain compliance obligations during the pandemic, the CFPB has also rescinded its 2018 bulletin (2018-01) that announced changes to supervisory communications.  The Bureau has replaced the 2018 bulletin with a new bulletin (2021-01).

In the 2018 bulletin, the Bureau announced that it…

The CFPB has issued “Supervisory Highlights COVID-19 Prioritized Assessments Special Edition.”

The report indicates that in May 2020, the Bureau rescheduled about half of its planned examinations and instead conducted prioritized assessments (PAs) in response to the COVID-19 pandemic.  The Bureau describes PAs as “higher-level inquiries than traditional examinations [that are] designed to…