I attended a great presentation by Ballard and Spahr regarding what happens at a CFPB exam. Speaking were one of their attorneys and a newly acquired former CFPB employee.
One of the questions that I get asked on a regular basis is: “How does the CFPB decide who they are going to examine?” The same question was asked in this session. Although I and countless others have asked this question, there was never a clear answer. While the answer is still not clear, it is much clearer!. In this webinar we were able to get a sneak peak into the prioritization process.
Apparently there is a formal prioritization process that takes into consideration multiple considerations in deciding who is next on the list.
As explained, there are multiple ways to receive information about a lender and the impact of those help to prioritize what lenders will be examined next.
They look at:
Size
Market Share
Potential for consumer harm
Field and market intelligence
Other regulator information and previous exams
It appears that the fastest way to get to the top of the list is to have complaints, market share and a perceived practice that is causing harm to many consumers.
Managing complaints both inside and outside of your company is so very important in today’s world.
What are you doing internally or externally to mitigate the complaint risk?
