5 Lessons from the CFPB’s Supervisory Highlights Report

Brian Lane
Baker Tilly

We reviewed the 7 Supervisory Highlights (SH) reports issued by the CFPB since their inception in 2011 and analyzed the issues raised in the reports and offered some practical action steps.  SH reports generally summarize the non-public actions taken by the CFPB as part of their supervision process.  While the public actions of the CFPB have obviously received a great deal of media and political attention, we think the issues noted in these reports can be of value to ARM companies.   Our observations:

Contrary to many pundits, not everything that the CFPB does gets escalated into a federal case.  By our reading, the CFPB noted 138 individual issues, showing that they are using discretion in escalating issues when conducted on-site inspections of regulated entities.

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