CFPB Releases Exam Procedures for IT Compliance Reviews

Guide covers best practices for compliance management systems and how IT programs can impact compliance with federal laws.

12/22/2021 2:30 P.M.

2 minute read

The new year is a good time to review policies and procedures and best practices for compliance management. While preparing for the Consumer Financial Protection Bureau’s release of Reg F, agencies—understandably—may have missed a recent guide from the bureau about information technology compliance.

The guide covers the CFPB’s examination procedures for agencies’ Compliance Management Systems (CMS) and how the use of information technology (IT) could impact compliance with federal consumer financial laws.

“As part of its overall CMS assessment, the CFPB may evaluate the technology controls of an institution and its service providers. The CFPB may also evaluate an institution’s IT as it relates to compliance with [f]ederal consumer financial laws,” the guide states.

View the complete guide here.

Supervisory Highlights

The CFPB also recently released its latest Supervisory Highlights report, an anonymized overview of the agency’s findings from examinations of regulated entities conducted between January 2021 and June 2021. Notably—at least for the accounts receivable management (ARM) industry—the report features only one entry relating to a debt collector’s violation of the Fair Debt Collection Practices Act, ACA International previously reported.

In addition to debt collection examinations, the report covers credit card account management, deposits; fair lending; mortgage servicing; payday lending; prepaid accounts; and remittance transfers. The report, released under the leadership of CFPB Director Rohit Chopra, covers the time that David Uejio served as acting director for the bureau prior to Chopra’s confirmation as director by the U.S. Senate in September.

The report shares information about the bureau’s examination findings, supervisory program developments and remedial actions, but it does not impose new or different legal requirements beyond those in relevant laws and regulations. The bureau disseminates this information to help institutions better understand how it examines regulated entities and to help those entities better comply with federal law.

Reg F Resources

ACA also has compliance resources for members on the Reg F Resource Center, including links to the rule and rule summaries, the ACA How: Reg F Implementation video series, archived ACA Huddle webinars on Reg F and more.

Check ACA’s online events calendar for upcoming education on compliance, operations, collector training and other topics.

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