September 26, 2022

Volume XII, Number 269


September 23, 2022

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CFPB Fall Supervisory Highlights Shed Light on Agency Priorities

Yesterday, the Consumer Financial Protection Bureau (CFPB) released its Fall Supervisory Highlights. The report covers examinations completed between January and June of 2021. Over the last year, the Biden-era CFPB has made various statements about its priorities. For instance, the Bureau has issued comments or taken action related to the small dollar lending agenda, auto financefintechs and technology companiesmortgage discrimination, and small business lending. The CFPB has been particularly vocal about COVID-19 issues, going so far as to publish a special edition of its Supervisory Highlights in January focusing entirely on issues related to the pandemic. However, the Bureau’s Fall Supervisory Highlights provide a more comprehensive picture of where the Chopra-led CFPB has expended effort and resources, and where industry stakeholders can expect continued scrutiny in the months and years ahead.

In particular, the Fall Supervisory Highlights cover a broad swath of issues, including fair lending, mortgage servicing, debt collection, small dollar and payday lending, student loan servicing, and credit card account management, among other items. Unsurprisingly, the Bureau continues to take a hard look at alleged legal violations arising out of the COVID-19 pandemic. According to CFPB Director Rohit Chopra, the report “reveals that irresponsible or mismanaged firms harmed Americans during the COVID-19 pandemic.” Consistent with the CFPB’s recently emphasized focus on fair lending issues, the report also identifies widespread purported fair lending violations in both the consumer and business finance spaces. The Bureau specifically stated that it is “committed to rooting out all forms of lending discrimination, including redlining.”

In total, the Fall Supervisory Highlights contain a detailed explanation of the CFPB’s findings that promise to shed light on how this version of the Bureau will flex its supervisory muscle. As such, each section of the report deserves its own detailed treatment. Over the next few weeks, Bradley Financial Services attorneys will publish detailed coverage of each of the Supervisory Highlights’ findings in this space in order to provide greater insight into the pulse of the Bureau. Stay tuned!

© 2022 Bradley Arant Boult Cummings LLPNational Law Review, Volume XI, Number 343

About this Author

Robert Maddox Financial Lawyer Bradley Arant Boult Cummings LLP

In the past decade, Robert Maddox handled more national/multi-state state attorneys general investigations and related consent judgments than any attorney in the United States.

His work involves representing clients before the CFPB, DOJ, EOUST, OCC, FRB, HUD, SEC and multiple state regulatory agencies, including banking, finance and insurance agencies.

With Bradley’s national competitive fee advantage, he continued the firm’s representation post-consent judgment on most matters to handle redress of business systems, internal and external reporting, and account remediation –...

Christopher Friedman Nashville Lawyer Bradley Arant Boult Cummings Law Firm

Chris Friedman is a regulatory compliance attorney and litigator who focuses on helping consumer finance companies and small business lenders, as well as banks, fintech companies, and other participants in the financial services industry, address the challenges of operating in a highly regulated sector. Chris focuses on both small business lenders and alternative business finance products and has helped non-bank small business lenders, banks who make small business loans, commercial credit counselors, lead generators, and others in the industry. He helps clients launch new products,...