On October 14, 2011 the Consumer Financial Protection Bureau (CFPB) published it’s Supervision and Examination Manual. The CFPB will begin it’s first examinations in the next few weeks.
The publication of the manual is a big deal, but is it a big deal for your institution? Probably not. The CFPB only examines institutions with more than $10 billion in assets, that group includes a little over 100 banks nationwide. So, if you are in that exclusive club, publication of the manual is a big deal.
If you are not in that club, publication of the manual is an interesting event, with a couple areas of note.
One area of interest is the new UDAAP standards. The Dodd-Frank added abusive acts and practices to the existing lineup of unfair and deceptive acts or practices. Very little guidance on the new abusive standard is available from any source, and the new manual does little to expand that guidance. The manual does provide a good summary of the existing guidance on UDAAP.
The manual also includes a simple to use risk assessment system. If you are implementing a new risk assessment process or replacing an existing process the template provides a well thought out risk assessment system.
The manual is available at https://www.consumerfinance.gov/guidance/supervision/manual/.
