CFPB Exams

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On Monday the CFPB released updated examination procedures for student loans.  This update revises and expands on a previous update that was released in December 2013 in conjunction with the CFPB’s “larger participants” rule for student loan servicers. The new procedures serve to offer CFPB examiners more detailed guidance for examining student loans servicers subject to the CFPB’s supervisory authority, including banks, private student loan lenders, and others servicers subject to CFPB supervision under the Bureau’s “larger participants” rule.… Continue Reading

I regularly work with technology innovators to help them get their ideas cleaned up for financial institutions and to give them a headstart in understanding the types of risk concerns and controls that financial institutions are going to have and want.  To technology innovators who may be intrigued by the CFPB’s request for dialogue, I wanted to provide my thoughts on some steps to take before charging through the Project Catalyst doors and throwing your ideas in front of the CFPB.… Continue Reading

Intensive examinations by the CFPB are expected to begin soon for debt collectors and debt buyers. To help you get prepared, the Association of Credit and Collection Professionals (ACA) is offering a teleseminar titled “Ready or Not: How to Prepare for a CFPB Examination.” Three members of Ballard Spahr’s CFS Group—Alan S.… Continue Reading

On March 9, I was on a panel of speakers at a City Bar Center for CLE titled “Consumer Finance Protection After Dodd-Frank:  The New Legislation’s Enhanced Enforcement Structure.”  Deepak Gupta, Senior Counsel for Enforcement Strategy at the CFPB, spoke on the same panel.  During my presentation, I raised serious concerns about a CFPB examination policy under which one or more CFPB enforcement attorneys are accompanying CFPB examiners on all CFPB exams. … Continue Reading