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Financial Services Law Insights and Observations

CFPB Releases Updated Supervision and Examination Materials

Consumer Finance CFPB FFIEC

Consumer Finance

On March 31, the CFPB released updates to sections of its Supervision and Examination Manual as required by the updated Federal Financial Institutions Examination Council’s Uniform Interagency Consumer Compliance Rating System. The revised CFPB Supervision Examination Cycle Overview highlights the continuous exam cycle from pre-examination/scoping procedures to the monitoring and corrective actions stage, and provides additional details on its “prioritization” approach to examining, which considers the “large number, size, and complexity of entities falling under its supervisory authority.” Updates were also made to the Examination Process which offers further details on the exam cycle. The updated Scope Summary template provides examination background information on the entity as well as details regarding prudential and state regulators, communication plans, institution product lines to be reviewed, complaints, outstanding enforcement actions or other open matters, and risk summaries. Lastly, updates have also been made to the Examination Report Template—which provides the scope of review and consumer compliance rating based on the findings of the exam—and the Supervisory Letter Template—which references matters requiring attention or that need to be corrected based on the Bureau’s review.