CFPB Releases Supervisory Highlights Report
The Consumer Financial Protection Bureau (CFPB) this week released a new Supervisory Highlights report. In doing so, it announced, “CFPB Exams Find Unfair, Deceptive, and Abusive Practices Across a Wide Array of Consumer Financial Product Lines.” While the headline may attract attention, it’s important for context to explain what Highlights is and is not.
The Bureau periodically publishes Highlights to share key examination findings. This latest edition covers findings from CFPB supervisory examinations completed from July 2022 to March 2023 in the areas of auto origination, auto servicing, consumer reporting, debt collection, deposits, fair lending, information technology, mortgage origination, mortgage servicing, payday and small dollar lending, and remittances.
Highlights is intended to communicate information about operational changes to the CFPB’s supervision program, using recent guidance documents in a convenient and accessible manner. Compliance professionals, for example, might gain insights into new or updated areas of focus in supervisory reviews drawn from specific examinations.
The CFPB makes clear that the findings in Highlights may pertain to one or more institutions; it does not specify if these findings are from a single exam, several exams, or a dozen exams. In other words, it is much more likely that the situations outlined in Highlights are unique and not standard industry practice.
So, while Supervisory Highlights can be a helpful tool in pulling actionable insights from specific reviews, it is not a trend report that draws industry wide conclusions about operations and practices of the consumer finance marketplace.
July 28th, 2023
