The Consumer Financial Protection Bureau (“CFPB”) has released procedures it will use in examining student lenders. The Student Lending Examination Procedures, available here, set forth the CFPB’s examination objectives and provide an outline of the “modules” that examiners will use in six examination areas: (1) Advertising, Marketing, and Lead Generation; (2) Customer Application, Qualification, Loan Origination, and Disbursement; (3) Loan Repayment, Account Maintenance, Payoff Processing, and Payment Plans; (4) Customer Inquiries and Complaints; (5) Collections, Accounts in Default, and Credit Reporting; and (6) Information Sharing and Privacy.
The procedures outline the steps examiners will use to evaluate private student lenders’ compliance with a host of federal consumer financial laws, including the Truth-in-Lending Act, Electronic Funds Transfer Act, Fair Debt Collection Practices Act, Fair Credit Reporting Act, Equal Credit Opportunity Act, and the Gramm-Leach-Bliley Act.
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