What are you waiting for? Time to prep for CFPB exam is before it is announced

The Consumer Financial Protection Bureau's supervision and enforcement jurisdiction is huge. In addition to large depositories, it also has authority over many nonbanks that were not previously under federal regulation—including all that offer, originate, broker or service mortgages. But even for institutions accustomed to U.S. government oversight, the bureau's exam approach is a new wrinkle. Unlike the prudential regulators, which have typically conducted far-reaching, cyclical exams using a team of examiners well-known to the institution, the CFPB is focusing on testing narrower slices of an institution's business at more irregular intervals, choosing those most likely to cause consumer harm. The CFPB's strategy also differs from state exams: Instead of just looking at loan-level results, the bureau also wants to test systems to make sure they don't allow or encourage undesirable outcomes. The bureau's approach to enforcement is also novel. It has the authority to go after individuals as well as entities. It can require that penalties include monies for harmed consumers. And it can use its subpoena-like Civil Investigative Demands powers to dig up evidence of potential violations by individuals and companies outside its supervisory authority. Learn more about the CFPB's supervision and examinations—and how you should prepare for and respond to them—in IMF's Guide to CFPB Mortgage Exams and Enforcement. In addition to sections that delve into CFPB oversight powers and the exam process, this special report offers tips for supervised entities on what to do before, during and after the CFPB comes knocking at the door. Partial Table of Contents CFPB Oversight Related Persons Civil Investigative Demands Litigation Remedies Issues with CFPB Supervisory Activities CFPB Exams Procedures Exam Process Reporting Results of Exams HMDA Transaction Testing Frequency of Exams Coordination with State Exams Tips for Supervised Entities Areas of Focus Privileged Information Risk Management Compliance Management Programs Consultation from Attorneys HMDA Compliance Management Servicing Characteristics of CFPB Enforcement Cases Prepare yourself for CFPB enforcement— before the bureau comes knocking at your door.

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