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Tag Archives: exams

CFPB releases report on fair credit exams and white paper on proxy methodology

Posted in Auto Finance, CFPB Exams, Fair Credit

Along with its proposed larger participant rule for the auto financing market, the CFPB recently issued a special edition of Supervisory Highlights (“report”) describing its fair credit supervisory activity in what it characterizes as “the indirect automobile lending market.” The report indicates that CFPB supervisory examination teams have been conducting targeted Equal Credit Opportunity Act… More >

OIG finds CFPB’s supervision program needs improvement

Posted in CFPB Exams

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… More >

CFPB will stop bringing enforcement attorneys to exams

Posted in CFPB Enforcement, CFPB Exams

Politico has reported that, effective November 1, the CFPB will end its practice of having enforcement attorneys regularly participate in examinations of supervised entities. According to the report, Director Cordray announced the change on a conference call with CFPB examiners. The report indicated that a CFPB spokeswoman attributed the change to an internal review that… More >

The role of CFPB enforcement attorneys at exams: the picture is getting clearer

Posted in CFPB Enforcement, CFPB Exams

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… More >

OIG to look at presence of CFPB enforcement attorneys in exams

Posted in CFPB Enforcement, CFPB Exams

The CFPB’s practice of bringing enforcement attorneys to examinations has been a continuing concern for industry.  In particular, supervised entities worry that the participation of enforcement attorneys in examinations inhibits free and open communication, and signals the CFPB’s intention to use the examination process as a development ground for enforcement actions.   We were pleased to… More >

The CFPB and privilege: the fight isn’t over

Posted in CFPB Enforcement, CFPB Exams

We blogged recently about H.R. 4014, which President Obama signed into law near the end of 2012.  The law identifies the CFPB as a regulator to whom a regulated entity may submit privileged information without waiving any state or federal law privilege and provides that the CFPB may share privileged information of a regulated entity with other… More >

More on enforcement attorneys and supervisory exams

Posted in CFPB Enforcement, CFPB Exams

The discussions at the ABA Consumer Financial Services Winter Meeting have reached biblical proportions (literally).  The participants on yesterday’s CFPB Exams and Enforcement panel read from the New Testament on “ravening wolves in sheep’s clothing” (later clarified as NOT a reference to CFPB enforcement attorneys) and how the “wise man built his house upon a… More >

Gotcha-free exams

Posted in CFPB Exams

I am at the ABA Consumer Financial Services Committee’s meeting in Naples, Florida.  (There is record attendance at this year’s meeting—nearly 225 consumer financial services lawyers.  I am sure that the CFPB deserves some credit for this.)  And yesterday morning, I listened to a panel on CFPB exams and enforcement actions on which Calvin Hagins,… More >

CFPB reorganizes supervision staff

Posted in CFPB Exams

The CFPB is reorganizing its headquarters staff for supervision so it will no longer be divided into separate offices for nonbank and large bank supervision.  While there will continue to be two offices, one office will now be focused on exams and the other will be focused on policy.  The exam office will oversee the… More >