A Perspective on CFPB Exams
and Customer Experience
“Begin with the end in mind”
~Stephen Covey
“Great service comes from the heart”
~Barbara Glanz
Agenda
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CFPB Goals/Outcomes
Exam Modules
Emphasis on Fair Lending
Process
Complaints
Lessons Learned
CFPB Goals/Outcomes
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The CFPB’s goals are to:
 Prevent financial harm to consumers while promoting good practices that benefit them
 Empower consumers to live better financial lives
 Inform the public, policy makers and the CFPB’s own policy-making with data driven
analysis of consumer finance markets and consumer behavior
 Advance the CFPB’s performance by maximizing resources and enhancing input
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The CFPB’s desired outcomes (in support of its goal of preventing
financial harm to consumers and promoting beneficial practices)
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Adoption of regulations
Supervise institutions to foster compliance with federal consumer financial laws
Enforce such laws
Hold violators “accountable”
Instead of establishing industry-wide standards through the
rulemaking process, the CFPB plans to use it supervisory and
enforcement authority to impose such standards
Exam Modules
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Fair Lending
Advertising Marketing
Qualification and Originations
Servicing
Collections
Complaints
Emphasis on Fair Lending
• Extraordinarily heavy emphasis on Fair Lending
 Advertising and Marketing module looks at Equal Credit
Opportunity and Regulation B
 Qualification and Originations module looks at all credit scoring and
automated underwriting for fair lending compliance
 Close scrutiny of:
 Lenders and service providers
 Underwriting and documentation practices
 Repayment options and payment posting
 Fees
 Disclosures
 Reporting
 Adequacy of statements
• Heavy disparate impact testing
• Track cases separately
Process
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Extensive questionnaires
Introductory “Set the Stage” meeting
Central point of contact
Careful review of answers (Legal/Compliance)
Central repository for data
 Security
 Indexing
 Controls
• Auditors
 Frequently change
 Prefer to work remotely, if possible
 Own their piece, perspective, pace and process
 Limited sharing
 Expect customized reporting (variations of the same request)
• Timeframes
Complaints
• The Complaints Module reviews the process for receiving,
tracking and responding to customer complaints.
• The definition of a complaint varies but in general appears
to include regular servicing requests.
• Policies and procedures are interchangeable.
• Line of business and corporate standards are expected to
be identical.
• Examiners have expectations that 100% of all calls are
recorded and kept indefinitely. This includes Executive
Office calls back to customers.
• Standards for oral and written complaints are expected to
be indistinguishable.
• Heavy focus on reporting and significant feedback is
offered for the reporting content and distribution.
• Review how does a “normal” customer get to an executive
or escalate.
Lessons Learned
1.
The CFPB exam is:
 A whole new ball game
 A significant time and resource investment
 All about the customer- and personal perceptions of customer
impacts
 Data, data, data
 Much more complex and different than any exam or audit
 New to them (and banks are complex entities)
 Enforcement oriented with limits to rebuttals
2. Documentation is key
3. Logistics are important
4. Scope is not always “as advertised”
Lessons Learned…
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“Surprises” are commonplace – may have to “agree to disagree”
The exam will last longer than they anticipate and perhaps you
ever dreamed