News & Analysis as of

Consumer Financial Protection Bureau (CFPB) Compliance Management Systems

Alston & Bird

HELOCs On the Rise: Is Your Servicing CMS Ready?

Alston & Bird on

A&B ABstract: The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has moved to clarify its regulatory authority at a time when the economic climate is ripe for a resurgence in HELOC lending. In an amicus brief...more

Buchalter

OCC Highlights Banks’ Compliance Staffing Issues, Even as Regulators Place More Compliance Demands on Banks and Place Executives...

Buchalter on

In its recent Semiannual Risk Perspective, the Office of the Comptroller of the Currency (OCC) has highlighted the difficulties banks face finding adequate numbers and quality of hires for compliance oversight. While there...more

Sheppard Mullin Richter & Hampton LLP

CFPB Updates Supervision and Examination Manual, Adds IT Examination

The CFPB updated its Supervision and Examination Manual by adding a new section titled Compliance Management Review – Information Technology. The new examination procedures are meant to assist CFPB examiners when assessing...more

Ballard Spahr LLP

CFPB adds new section on information technology to Supervision and Examination Manual

Ballard Spahr LLP on

The CFPB has added a new section to its Supervision and Examination Manual titled “Compliance Management Review-Information Technology.” The new section supplements the existing section on Compliance Management Review to...more

Hudson Cook, LLP

Learning from the Mistakes of Others— CFPB's Summer 2021 Supervisory Highlights

Hudson Cook, LLP on

Most creditors find 100% regulatory compliance to be an elusive goal, and auto-secured creditors are no exception. My clients often say to me, "Gee, I would have fixed that compliance gap if I had only known it was there!"...more

Hudson Cook, LLP

CFPB Bites of the Month - Q&A with Lucy Morris: Takeaways from 10 Years

Hudson Cook, LLP on

Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. With July 21, 2021 marking...more

Ballard Spahr LLP

CFPB rescinds 2018 bulletin on supervisory communications and issues replacement bulletin eliminating supervisory recommendations

Ballard Spahr LLP on

In addition to rescinding seven policy statements providing flexibility to companies in meeting certain compliance obligations during the pandemic, the CFPB has also rescinded its 2018 bulletin (2018-01) that announced...more

Davis Wright Tremaine LLP

CFPB Issues Guidelines Encouraging Access to Financial Products and Services for Customers with Limited English Proficiency

Approximately 22 percent of U.S. residents over the age of 5 speak a language other than English at home. Of those persons, approximately 37.6 percent have limited English proficiency (LEP), meaning they have a limited...more

Hudson Cook, LLP

What Does a Biden/Harris Administration Mean for Auto Sales and Finance?

Hudson Cook, LLP on

So, the general consensus is that a Biden/Harris Administration will mean lots of change for automotive finance. But, exactly what types of change and how quickly will that change occur? And, just how bad for the industry...more

Ballard Spahr LLP

CFPB issues policy statement on applications for early termination of administrative consent orders

Ballard Spahr LLP on

The CFPB has issued a “Statement of Policy on Applications for Early Termination of Consent Orders.” The statement is applicable as of today....more

Bradley Arant Boult Cummings LLP

New FAQ Responses to Small Dollar Rule Address Auto and Mortgage Lending, Payment Transfers and Notices Inclusion

On Tuesday, August 11, 2020, the CFPB issued a second round of answers to frequently asked questions related to the Small Dollar Rule. The FAQ responses range from addressing more nuanced provisions of the payment provision...more

Foodman CPAs & Advisors

Cumplimiento OFAC de las Instituciones Financieras y las Agencias Reguladoras Bancarias

Mientras que la OFAC es responsable de promulgar, desarrollar y administrar sanciones para el Secretario del Tesoro de EE. UU., las agencias reguladoras bancarias cooperan para asegurar el cumplimiento de las instituciones...more

Foodman CPAs & Advisors

Financial Institution OFAC Compliance and Bank Regulatory Agencies

While OFAC is responsible for promulgating, developing, and administering sanctions for the U.S. Secretary of the Treasury, bank regulatory agencies cooperate in ensuring OFAC financial institution compliance.  ...more

Ballard Spahr LLP

CFPB issues policy statement on compliance resources

Ballard Spahr LLP on

The CFPB published a policy statement in today’s Federal Register to announce that, going forward, it is establishing a new “Compliance Aids” designation for certain Bureau guidance.  The policy statement becomes applicable...more

Hudson Cook, LLP

Welcome to the Sunshine

Hudson Cook, LLP on

Life under a rock has its benefits - you probably don't get many houseguests, and you're never sunburned. But there are some drawbacks, too. The main one is that you definitely don't know what's been going on out here in the...more

Troutman Pepper

Establishing an Effective Compliance Management System for Financial Services

Troutman Pepper on

The CFPB has generated acute awareness of the term “compliance management system” (CMS) through its highly publicized consent orders. Since it began issuing orders in 2011, the CFPB has invariably cited “significant...more

Baker Donelson

Not All Compliance Management Systems (CMS) are Created Equal

Baker Donelson on

While the CFPB continues to expand into various business lines and increase the number of industries they supervise and hold enforcement power over, the FDIC, FED and various state regulators have all incorporated the CFPB's...more

Smith Debnam Narron Drake Saintsing & Myers,...

CFPB Consent Orders with Consumer Reporting Agencies Focus on Marketing Practices not Credit Reporting

Marketing practices remain at the forefront of CFPB activity as evidenced by two recent consent orders entered into with TransUnion and Equifax. The consent orders combine to require the CRAs to pay more than $17.6 million...more

Smith Debnam Narron Drake Saintsing & Myers,...

Two More Banks Fall to Redlining Consent Orders

The Department of Justice has entered into a proposed consent order with two Ohio based banks resolving allegations that the banks engaged in a pattern or practice of redlining in their mortgage lending practices by...more

Smith Debnam Narron Drake Saintsing & Myers,...

CFPB Supervisory Highlights: It’s all about the Compliance Management System

The CFPB published its Fall Supervisory Highlights last week, highlighting its examination observations across various financial products for examinations conducted between May and August 2016. The Report highlights key...more

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