CFPB Expands Its Examination Manual to Include a New Section on IT

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The CFPB has recently added to its Examination Manual a new section, “Compliance Management Review – Information Technology”.  This new section is part of the Compliance Management System review. 

The CMS-IT examination manual contains five Modules as follows:  

  • Module 1: Board and Management Oversight
  • Module 2: Compliance Program
  • Module 3: Service Provider Oversight
  • Module 4: Violations of Law and Consumer Harm
  • Module 5: Examiner Conclusions and Wrap-Up

In the summary of this new section, the CFPB now makes the evaluation of an institution’s technology controls and its service providers part of the overall CMS assessment. 

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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