Monday, October 17, 2011

More Regulation - More Examinations - is it any wonder lenders are getting out?

On 10/13 the Consumer Financial Protection Bureau Released it's First Edition of Supervision and Examination Manual

If you have been through an audit in the past, you know that examiners use checklists and interviews to review and compile results.  While you may have been used to long questionnaire, this procedure with over 200 pages and 30 pages of NEW sample checklists, raises the level of review from granular to picayune.  

According to law firm Buckley and Sandler, "The manual is intended to be used by CFPB examiners to monitor the compliance with federal consumer financial laws by banks, thrifts, credit unions and non-depository companies that provide consumer financial products and services. The manual incorporates examination procedures developed under the auspices of the Federal Financial Institutions Examination Council (FFIEC) for many of the laws now generally enforced by the CFPB, including TILA, RESPA, ECOA and the FCRA. The manual also will include procedures for examinations of specific business lines. The initial edition of the manual includes procedures for examination of mortgage servicing activities of covered institutions. As described in the manual, CFPB examiners will work to assess compliance with federal consumer financial laws, obtain information about activities and compliance systems or procedures, detect and assess risks to consumers and to markets for consumer financial products and services, coordinate with other federal and state regulators, and use, where possible, publicly available information and existing reports to federal or state regulators when examining institutions."

For a copy of the manual, please see

See you on the breadline...

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