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The Consumer Financial Protection Bureau is the first regulator to be given direct supervisory authority over collection agencies and debt buyers, including onsite examinations and business audits for larger companies.

The CFPB Primer lays out what you'll need to have prepared for a CFPB Examination or Audit. Though currently, the CFPB is only examining Large Market Participants in the debt collection industry, most LMPs outsource some businesses to smaller agencies, making them affected participants, and likely to be audited by their business partners in a similar fashion to the CFPB. This resource is a terrific way to begin preparing for compliance audits of any kind.

You'll Learn:

  • Why it's important for agency policies to mirror day-to-day practices
  • How to flesh out key components of your policies and procedures
  • What the CFPB does behind the scenes to prepare for an examination of a collection agency

Table of Contents

  1. Introduction
  2. Whom Will They Supervise?
  3. List of CFPB Documents
  4. CFPB Examination Guide-Full Document
  5. CFPB Examination Guide-Debt Collection
  6. CFPB Bulletin on UDAAP (Bulletin 2013-07)
  7. CFPB Bulletin on Discussion of Debt Payments/Credit Reports (Bulletin 2013-08)
  8. What Does the CFPB Expect Me to Have in Place?
  9. What oversight do they want to see from the Board and Management?
  10. What steps should the Compliance Committee be taking?
  11. What do they want to see from my Compliance Program?
  12. Who is responsible for my CMS?
  13. What do they want to see from my Policies and Procedures?
  14. What do they expect from my Training Program?
  15. What will they look for in my consumer complaint records?
  16. How do I know if my Policies and Procedures are enough?
  17. More Questions to check in your policies
  18. What should I include in my Monitoring Program?
  19. What do they want to see from my Audit and Review program?
  20. Telling the Story
  21. What Should I Have Ready for an Examination?
  22. Where Do I Start?
  23. How will I know if the CFPB is going to examine my organization?
  24. Civil Investigative Demand
  25. What Should I Do?
  26. Response to the CID
  27. Confidentiality of the CID
  28. How will the examination flow and what are they going to review?
  29. Now What?

Author: Compliance Professionals Forum

Length: 20 pages