CFPB Audits: Being Prepared and Staying Compliant
|Date / Time:
Preparing for and responding to one of the Consumer Financial Protection Bureau's (CFPB's) examinations can be a daunting task, particularly for institutions that are under prepared.
This topic helps the persons responsible for preparing for the CFPB examination/audit understand how to prepare for the examination/audit. In addition, you will be provided with practical advice for responding to the CFPB. You also will identify recent trends in CFPB public enforcement and supervisory efforts which may be indicative of future CFPB priorities during an examination/audit.
How to Prepare for a CFPB Examination
What to Expect During an Examination
- The Compliance Management System – the Narrative
- The Product
- Origination; Advertising
- Specific Statutory Compliance
- Unfair, Deceptive and Abusive Acts and Practices
Recent Trends in CFPB Supervisory Efforts and Enforcement Actions
- The Cost of an Examination:
- The Monetary Costs and Other Expenses the Company Will Incur to Respond to a Civil Investigative Demand
- Overview of the Timing Elements of an Examination Including the Time Constraints for the Initial Responses and Then Various Other Deadlines Throughout the Examination
- Expectations Regarding Other Company Resources and Temporary Changes to Business Operations During an Examination
- The Content of the Civil Investigative Demand
- The Various Types of Requests of Information
- The Breadth of the Information Requests
- How the Information Must Be Produced to the CFPB
- The Follow-up and Waiting Game
- After the Initial Production of Information, the CFPB May Have Followup Requests for Information
- Waiting for the Results and What to Expect to Receive From the CFPB Including Fines and Improvements to Business Practices
About The Presenters
- Supervisory Highlights
- Mortgage Servicing; Debt Collection
- Student Loan Servicing
- Indirect Auto Lending; Small Dollar Lending
- Deposits; Fair Lending
- Enforcement Actions
- Mortgage Origination and Servicing
- Debt Collection; Auto Lending
- Deposits; Credit Cards/Addon Products
Jeffrey P. Barringer
Susan E. Chylik
- Associate in the Albany office of McGlinchey Stafford PLLC
- Practice emphasizes all aspects of state and federal consumer financial services regulatory compliance for creditors/servicers operating in several states or nationally
- Regularly assists creditors/servicers respond to regulatory inquiries and examination issues
- Regularly presents on regulatory compliance issues relating to mortgage origination
- American Bar Association, member, Consumer Financial Services Committee, Young Lawyer Liaison to the Truth in Lending Subcommittee; New York State Bar Association
- J.D. degree, summa cum laude, Albany Law School
Robert W. Savoie
- Associate in the Cleveland office of McGlinchey Stafford PLLC
- Represents banks, finance companies, mortgage companies and consumer lenders advising them on regulatory compliance for consumer loan documentation, e-commerce, underwriting, and servicing and collections practices
- Assists companies in responding to state and federal examinations, including Civil Investigative Demands issued by the CFPB
- Presents annually at the Wolters Kluwer and McGlinchey Stafford Consumer Financial Services Conference on servicing issues affecting the financial services industry
- American Bar Association Consumer Financial Services Committee, member and Young Lawyer Liaison to the Personal Property Subcommittee; Ohio State Bar Association member
- J.D. degree, The Ohio State University Moritz College of Law
- Associate in the New Orleans office of McGlinchey Stafford PLLC
- Practice regularly involves assisting state and national banks, mortgage lenders, motor vehicle sales finance companies, and small dollar lenders with substantive consumer financial services compliance and with CFPB and other governmental agency examinations and civil investigative demands
- Conducted presentations on a wide variety of topics, ranging from debt collection issues and mortgage servicing rules for American Bar Association meetings and webinars to Servicemembers’ Civil Relief Act compliance in the context of Department of Justice examinations
- Published articles on subjects ranging from mortgage servicing to debit card interchange fees to mortgage foreclosure compliance
- American Bar Association, member, Consumer Financial Services Committee, Young Lawyer Liaison to the Small Dollar Lending Task Force
- J.D. degree, Notre Dame Law School
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