7 Key Compliance Reminders from the CFPB

We've highlighted seven of the regulatory compliance reminders covered in the CFPB's annual "Supervisory Highlights" report. Check out these key elements to consider and a few compliance best practice guidelines.

The CFPB publishes their annual Supervisory Highlights in order to “share general information about examination findings without identifying specific institutions (except for public enforcement actions).”  The document serves as a large billboard of reminders for financial institutions.

Here are the seven key compliance reminders pulled from the CFPB's fall report, and some best practices:

1. Debt Collection: Do not threaten consumers with litigation you do not intend to pursue.
2. HMDA Data: Continue to evaluate the accuracy of your HMDA data (data integrity). The CFPB found "inadequate compliance management systems and severely compromised mortgage lending data."
3. Mortgage Servicing: Supervision efforts were focused on examining compliance of the new mortgage servicing rules. Servicers should have policies and procedures related to oversight of service providers.
4. Mortgage Loss Mitigation: Promptly and consistently convert trial modifications to permanent modifications after the successful completion of the trial.
5. Deposits: Consumers may report a deposit-related error either orally or in writing. Financial institutions must begin investigations promptly upon receipt of an oral notice.
6. Student Loans: Do not charge late fees during the grace period, as that may be considered unfair and deceptive.
7. Consumer Reporting Agencies: Handle disputes in a consistent fashion regardless of the originating source of dispute, i.e. telephone vs. written submission. Maintain a more formal complaint management system to effectively manage consumer complaints.

TRUPOINT Viewpoint: In the opening remarks of the Supervisory Highlights, the CFPB noted that supervised entities have improved their compliance management systems. The CFBP also acknowledged that both banks and non-banks have increased resources dedicated to compliance, changed reporting structures to give compliance more exposure, and improved instances of self-identified issues.

However, the regulators are still holistically investigating financial institutions' Compliance Management Systems. This fall report should not be perceived as a guide for the CFPB's sole areas of focus. Prior issues still must be considered when planning for 2015.

Prep for compliance success in two essential steps with our new, free eBrief. Click on the image at the right to get it! You'll learn the top compliance concerns of 2015, tips for how to help management understand why compliance is so important, and a couple of worksheets to improve collaboration.

To read the CFPB's full report (and past reports), click the link below.