• CFPB Releases Updated Compliance Manual
  • November 9, 2017 | Authors: Michele Bresnick Walsh; Robert A. Gaumont; Marjorie A. Corwin; Christopher R. Rahl; Andrew Keith Wichmann
  • Law Firm: Gordon Feinblatt LLC - Baltimore Office
  • The Consumer Financial Protection Bureau (CFPB) recently releasedrevisions to the compliance management review portion of its Supervision and Examination Manual. The updated examination procedures stress the importance of maintaining an effective compliance management system (CMS). The recent release contains five modules: (1) board and management oversight; (2) compliance program; (3) service provider oversight; (4) violations of law and consumer harm; and (5) examiner conclusions and wrap-up. The CFPB’s release stresses that an effective CMS must contain two independent control components: (1) board and management oversight; and (2) a strong compliance program. The CFPB expects an institution’s board/management to be committed to the institution’s CMS and have an effective change management process (including responding to internal and external changes). The CFPB also expects an institution to have a compliance program that includes effective, well-documented policies and procedures; training that effectively communicates the institution’s policies and procedures; regular monitoring/audits of the institution’s compliance with its policies and procedures; and a responsive and organized process for receiving, tracking, and responding to consumer complaints. The recent release also stresses the importance of proper third party service provider oversight and an effective process to self-identify and address violations of law and instances of consumer harm. For more information about CFPB compliance management expectations, please contact Christopher Rahl or Marjorie Corwin.