The truth is that preparing for a Consumer Financial Protection Bureau exam means implementing the requirements set forth in the
Indeed, the manner in which the CFPB conducts examinations is firmly rooted in identifying organizations’ historical adherence to the exam manual. For instance, the agency will talk to loan officers, identify if and when they were trained on the company’s procedures and policies, and whether they understand them. Management will typically be interviewed to determine its level of understanding of compliance rules. The CFPB will ask for various reports and memoranda wherein compliance issues were discussed, and it is fully expected such memoranda exist as part of the ongoing evaluation and monitoring of the compliance infrastructure. In fact, the very reporting structure, and the powers and duties of the chief compliance officer position will be evaluated within the organization to determine an organizations “commitment to compliance.” In all of these instances, the fact that the CFPB is looking back historically renders it impossible to create an appearance of compliance in a company that until the immediate past did not place a sufficient priority on such matters.
The facts are that an entity needs to start preparing for a CFPB examination (and examinations of state regulators that will soon mimic the CFPB in many respects) today. The first step is understanding what is now required of you and taking an overall reevaluation of the compliance position and infrastructure in light of these demands. It is not a fun thing to think about or focus upon, but it is something that every banker will need to consider sooner or later. In the event you wait until later, it will probably be too late.
