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The Federal Financial Institutions Examination Council (FFIEC), whose members include the CFPB, is proposing a new uniform interagency consumer compliance rating system to reflect changes in consumer compliance supervision since the current rating system was adopted in 1980.  The other FFIEC members are the Fed, FDIC, NCUA, OCC and State Liaison Committee. … 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 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 updated work plan as of August 30, 2013 of the Office of Inspector General (OIG) for the Fed and CFPB describes various CFPB projects that are “in progress” or “planned.” 

The projects listed as “work in progress” items include:

  • Evaluation of the CFPB’s integration of enforcement attorneys into examinations.  The CFPB’s practice of bringing enforcement attorneys to examinations has been a continuing concern for industry. 
… Continue Reading

The CFPB announced earlier this week that it has established a “framework” with the Conference of State Bank Supervisors (CSBS)  for coordination among the CFPB and state regulators on supervision and enforcement matters.  The framework states that it is “intended to establish a process for coordinated federal/state consumer protection supervision and enforcement of entities providing consumer products or services that are subject to concurrent jurisdiction of the CFPB and one or more [state financial regulatory authorities].” … Continue Reading

Remarks made by Ori Lev, the CFPB’s Deputy Enforcement Director for Litigation, at the ABA Consumer Financial Services Committee’s spring meeting last week further clarified the role of CFPB enforcement attorneys in CFPB exams. His remarks, coupled with comments made by another CFPB official at the Committee’s winter meeting, leave no doubt that the enforcement attorneys are much more than passive observers. … Continue Reading