CFPB Compliance Myths That Deserve Debunking

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When it comes to the Consumer Financial Protection Bureau’s ("CFPB" or the "Bureau") compliance expectations, it is important to separate myth from fact. These days, the CFPB is moving full-steam ahead on examining non-banks and banks, dozens at a time, and is not leaving any stone unturned for potential unfair, deceptive or abusive acts or practices in violation of the Consumer Financial Protection Act or other consumer financial laws that fall under its scope.

Myth #1: Only large financial institutions are subject to CFPB supervision and examination.

No provider of consumer financial products and services, or their service providers, should assume they are beyond the reach of the CFPB. The CFPB can examine any entity, regardless of size, based on regulatory authority to supervise "risky" financial products and services that it believes are causing harm to consumers. This authority is in addition to the CFPB's ability to supervise larger market participants in the debt collection, credit reporting, and student loan servicing markets, as well non-bank businesses in the private student loan, mortgage, and small dollar loan markets. (The CFPB also supervises banks with over $10 billion in assets).

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Topics:  Banks, CFPA, CFPB, Compliance, Enforcement, Nonbank Firms, Unfair or Deceptive Trade Practices

Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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