Federal Reserve Board Inspector General Reviewing CFPB's Use of Enforcement Attorneys During Examinations

CFPB Examination Enforcement

Recently, the Federal Reserve Board’s Office of Inspector General (OIG), which also serves as the OIG for the CFPB, released an updated Work Plan. The Work Plan includes as a “work in progress,” an evaluation of the CFPB’s integration of enforcement attorneys into its examinations of financial institutions. According to the Plan, the OIG is assessing (i) the potential risks associated with this examination approach and (ii) the effectiveness of any safeguards that the CFPB has adopted to mitigate the potential risks associated with this approach. Banks and nonbanks have previously expressed concern with the CFPB’s approach, which differs from the traditional approach taken by other federal regulators. In fact, in November 2012, the CFPB Ombudsman recommended that the CFPB review its implementation of the policy. The Work Plan states that the OIG expects to complete its review during the second quarter of 2013.