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In today’s podcast episode, we are joined by Raj Date, who has served in a variety of roles at the Consumer Financial Protection Bureau, including as the acting head of the agency and as it’s first-ever Deputy Director. He recently wrote a thought-provoking article in a new online publication, Open Banker, entitled “Banks Aren’t Over-Regulated, They Are Over-Supervised.”… Continue Reading

The Federal Deposit Insurance Corporation has announced that it is launching a new Banker Engagement Site (BES) this month through FDICconnect to serve as the primary tool for exchanging examination planning and other information for consumer compliance and Community Reinvestment Act (CRA) activities.  (The FDIC examines state-chartered banks that are not members of the Federal Reserve System.)  … Continue Reading

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. … Continue Reading

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) review.… Continue Reading

Yesterday, U.S. District Court Judge Timothy J. Kelly denied Leandra English’s motion for a preliminary injunction in a 46-page opinion. English had sought to block President Trump’s appointment of Mick Mulvaney to serve as the CFPB’s Acting Director. The Court denied that request and held that English failed to satisfy  any of the four elements of her preliminary injunction claim.… Continue Reading

The Office of Inspector General (OIG) for the CFPB and Fed has issued a report that found the CFPB can improve its practices related to examination workpaper documentation.  This report follows another OIG report issued last month that found the CFPB could improve the effectiveness of its Examiner Commissioning and On-the-Job Training Programs.… Continue Reading

In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI).

The bulletin is intended to assist supervised entities in complying with the CFPB’s regulations governing the use and disclosure of CSI (12 CFR Part 1070).  In the bulletin, the CFPB reviews the definition of CSI, which includes: reports of examinations, inspections and visitations; any documents, including examination reports, prepared by, or on behalf of, or for the use of the CFPB or any other federal, state or foreign government agency in the exercise of supervisory authority over a financial institution; any communications between the CFPB and a supervised entity or a federal, state, or foreign government agency related to the CFPB’s supervision of the entity; any information provided to the CFPB by a supervised entity to enable the CFPB to monitor for consumer risk in the offering or provision of consumer financial products or services or to assess whether an entity is a covered person or subject to CFPB supervisory authority; and information that is exempt from disclosure under certain provisions of FOIA.… Continue Reading

Last week, the CFPB’s Ombudsman’s Office issued its third annual report covering the Office’s activities during fiscal year 2014 (October 1, 2013 through September 30, 2014).  The role of the Ombudsman’s Office is to assist in the resolution of individual and systemic issues that a depository entity, non-depository entity or consumer has with the CFPB.… Continue Reading

In its Spring 2014 Supervisory Highlights report issued yesterday, the CFPB highlighted deficiencies and violations it found during examinations of consumer reporting agencies (CRAs), debt collectors and payday lenders.  The CFPB has authority to examine entities that qualify as “larger participants” under the final rules it adopted to supervise participants in the debt collection and consumer reporting markets and to examine payday lenders regardless of their size.… Continue Reading

Earlier this week, the results of an evaluation of the CFPB’s supervision program conducted by the Office of Inspector General (OIG) that the CFPB shares with the Fed were released in a report entitled “The CFPB Can Improve the Efficiency and Effectiveness of Its Supervisory Activities.”  The report is based on data in the CFPB’s Supervisory Examination System (SES) database as of July 31, 2013. … Continue Reading