examination procedures

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures reflect the Department of Defense’s July 2015 final rule and August 2016 interpretive rule and appear consistent with those released by the CFPB

The Office of the Comptroller of the Currency has released revised TILA and RESPA chapters of its examination manual for consumer compliance exams.  The revised chapters incorporate the detailed procedural and substantive requirements of the CFPB’s TILA/RESPA integrated disclosures (TRID) rule, which is set to go into effect on August 1, 2015.  The OCC’s publication

In conjunction with issuing its final “larger participant” rule for student loan servicers last week, the CFPB also revised its education loan examination procedures.  The revisions are intended to provide more extensive guidance for examiners to follow when examining student loan servicing by entities subject to the CFPB’s supervisory authority, whether banks or private

Today, the CFPB proposed a rule setting up procedures for supervising non-banks that the CFPB believes are engaging in, or may have engaged in, activities that pose risks to consumers. Under the Dodd-Frank Act, the CFPB has authority to supervise any nonbank that it has reasonable cause to determine is engaging in, or has engaged,

On April 13, 2012, the Consumer Financial Protection Bureau (CFPB) released Bulletin 2012-03, which stated that the CFPB will expand its examination scope beyond supervised institutions themselves and examine their service providers as well.  If the CFPB believes that service providers are not complying with a consumer financial services law, or are committing a

We’ve taken a look at the CFPB’s just-issued Short-Term, Small-Dollar Lending Examination Procedures, the latest update to the CFPB’s larger Supervision and Examination Manual, and think there are several noteworthy highlights.

The procedures apply broadly to both closed-end and open-end loans that involve small dollar amounts, short-term repayment periods and lender access to the

Prepared remarks delivered by Richard Cordray at the CFPB’s field hearing on payday lending today in Birmingham, Alabama identify some of the initial issues on which the CFPB will likely be focusing. Mr. Cordray indicated that the CFPB plans to “dig deep” on the topic of “repeated long-term use of payday loans” and described a