On May 22, 2014, the Consumer Financial Protection Bureau (CFPB or the Bureau) released its Spring 2014 Supervisory Highlights report, which addresses the agency’s supervisory activities during the last six months (spanning November 2013-February 2014). The report focuses on the Bureau’s nonbank supervisory efforts and in particular on its examination findings in three industries: consumer reporting agencies; debt collection; and short-term, small dollar lending (or payday lending).
The report also focuses on two more general regulatory concerns: the maintenance of adequate compliance management systems (CMS) and the importance of vendor management. Specifically, the report notes that adequate CMS have “four interdependent control components,” which include management and oversight by the board of directors; a compliance program; a consumer complaint management program; and an independent compliance audit. Throughout the report, the Bureau also reiterates its expectation that all supervised entities will manage carefully their vendor relationships; the Bureau first addressed this issue in its Bulletin dated April 13, 2012.
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