The payday loan industry is abuzz with the news that the CFPB has commenced its initial payday lender exam, operating in tandem with state examiners and providing virtually no advance warning. This news comes on top of a report that the CFPB has begun to examine non-bank mortgage companies. It should serve as yet another warning to payday lenders, student lenders, mortgage lenders and companies that might soon become “larger participants” in a market for consumer financial services that they urgently need to get their act in gear and ensure that their federal-law compliance is up-to-speed. This includes not only compliance with the federal statutes that the CFPB inherited from other federal agencies but also compliance with the new requirement under Dodd-Frank that a company not engage in “abusive” acts or practices. We are assisting a number of companies in performing self-assessments of their compliance and crafting or updating required policies. This is a situation where an ounce of prevention is certainly worth a pound of cure.