All You Need to Know About CFPB Exam Is in the Manual

February 13, 2012

With the recess appointment of the director of the Consumer Financial Protection Bureau, the agency is becoming even more active and issues are coming into focus. Financial institutions subject to its jurisdiction should pay attention to its Supervision and Examination Manual published in late 2011.

Having started my career in consumer protection at the Office of the Comptroller of the Currency when many of the current consumer protection regulations were promulgated, it is clear to me that the focus of this agency will differ from that which most financial institutions are accustomed to. One need look no further than the fact that the agency was given not only administrative enforcement authority, but also, in stark contrast to the federal banking agencies, the right to bring civil litigation in court, to understand the focus that the agency brings to consumer protection. To read the full analysis, please click here.