Preview of Coming Attractions: Consumer Financial Protection Bureau Publishes New Supervision and Examination Manual

The Consumer Financial Protection Bureau (“CFPB”) has published its Supervision and Examination Manual – Version 1.0 (“Manual”) to serve as a guide for CFPB staff in supervising and examining consumer financial services companies under the jurisdiction of the CFPB for compliance with the federal consumer financial protection laws enforced by the CFPB. The CFPB has indicated that the Manual is a work in process. The guidance will continually be refined in subsequent editions based on feedback from the examination staff at the CFPB, banking industry, non-depository financial services companies (“NDFSCs”), federal and state agencies, consumer advocates, and others.

Some of this will be familiar to you, since the Manual incorporates many of the examination procedures previously developed by the Federal Financial Institutions Examination Council (“FFIEC”) and adopts the same compliance risk management approach embodied in the compliance procedures previously used by the federal bank regulatory agencies, including the explicit adoption of the Uniform Consumer Compliance Rating System. The Manual is not, however, a carbon copy of prior examination guidance. The CFPB has clearly identified “risk to consumers” as the primary focus of its regulatory supervision, enforcement policy, and actions. The heightened attention to unfair, deceptive, or abusive practices and fair lending compliance is also evident in the Manual.

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