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Consumer Financial Protection Bureau R egional Supervision Overview for CMLA Presented by Peggy Atcher October 19, 201

Consumer Financial Protection Bureau R egional Supervision Overview for CMLA Presented by Peggy Atcher October 19, 2012. CFPB Supervision. Core CFPB Functions: • Conduct rule-making, supervision, and enforcement for Federal consumer financial protection laws.

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Consumer Financial Protection Bureau R egional Supervision Overview for CMLA Presented by Peggy Atcher October 19, 201

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  1. Consumer Financial Protection Bureau Regional Supervision Overview for CMLA Presented by Peggy Atcher October 19, 2012

  2. CFPB Supervision • Core CFPB Functions: • • Conduct rule-making, supervision, and enforcement for Federal consumer financial protection laws. • • Restrict unfair, deceptive, or abusive acts or practices. • • Take consumer complaints. • • Promote financial education. • • Research consumer behavior. • Monitor financial markets for new risks to consumers. • Enforce laws that outlaw discrimination and other unfair treatment in consumer finance. October 19, 2012 2

  3. CFPB Supervision October 19, 2012 3

  4. CFPB Supervision Coordination within CFPB October 19, 2012 4

  5. CFPB SupervisionApproach to Supervision • Risk to Consumer. • Data Analysis. • Consistency across all supervised entities. October 19, 2012 5

  6. Depository Institution Supervision Process • Assess each institution’s internal ability • to detect, prevent, and remedy harm • to consumers • Look at products and services the • institution offers, with a focus on risk • to consumers. Compliance will be assessed, including how a product • is developed, marketed, sold and • managed • Fair lending reviews will be conducted • The CFPB can seek corrective action • to help strengthen company’s programs and processes HUD Final Rule October 19, 2012 6

  7. CFPB Supervision • CFPB Supervision and Examination Manual • (October 2011) • Provides guidance to CFPB examiners to: • Review the operations of supervised entities. • Check compliance with consumer protection laws. • Prepare for and conduct an examination. • Conduct consistent reviews of supervised entities. October 19, 2012 7

  8. CFPB SupervisionExamination Procedures • Compliance Management Review. • UDAAP as Overlay Consideration. • Interagency Procedures: • ECOA, HMDA, TILA, RESPA, etc. • Product-Specific Procedures: • Mortgage Servicing • Mortgage Origination • Payday Lending • Others in Development

  9. CFPB Supervision • Risk Assessment Overview • Evaluate: in order to: • Inherent Risk to • Consumers Identify & Prioritize • As mitigated by Examination Reviews • Effectiveness of • Compliance • Direction of Risk • Prioritize Reviews and Examinations October 19, 2012 9

  10. CFPB Supervision • Product Reviews • Effectiveness of Compliance Management in preventing violations of Federal consumer protection laws. • Compliance with such laws. • Avoidance of UDAAP & other risks to consumers. October 19, 2012 10

  11. CFPB Supervision • Product Review Example – Mortgage Servicing • 3 Areas of Review: • Routine Servicing of a Mortgage Loan. • Default Servicing. • Foreclosure. October 19, 2012 11

  12. CFPB Supervision • Early Observations… • Questions? • CFPB website - www.consumerfinance.gov October 19, 2012 12

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