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CFPB, the Automotive Industry, Technological Services and Beyond

Who needs to be prepared for the CFPB exam and who does it affect?

The Consumer Financial Protection Bureau (CFPB) Exam is an extensive audit to supervise consumer finance markets including:

  • Banks
  • Credit unions
  • Financial agencies
  • Debt collection agencies

However, financial institutions are not the only ones that need to be prepared in the event of a CFPB examination. In 2012, the CFPB released a document holding vendors working with financial agencies responsible for upholding CFPB standards both legally and fiscally. This specifically targets technology companies and settlement providers that work in conjunction with financial institutions – making it necessary that they are prepared in the event that the CFPB requests examination. For those involved in the mortgage industry, this became apparent on October 3rd, 2015 when TILA, or the Truth in Lending Act and RESPA, or the Real Estate Settlement Procedures Act both combined for the first official day of enforcement for the TILA-RESPA Integrated Disclosures (TRID) rules.

The oversight of the CFPB continues to grow. In June 2015, the CFPB became permitted to audit non-bank automotive financing companies and their vendors. This ruling became effective August 9th, and there have already been $48 million in automotive payouts.

Why does it matter?

CFPB-fines

As of 2014, the CFPB has order 4.6 billion in relief to consumers for violation of CFPB laws, and another $150 million in civil penalties. There is no indication of these fine numbers dropping, as they have grown annually at a rate of about 10% as the CFPB jurisdiction continues to grow.

What can you do?

In order to protect yourself and your assets from CFPB claims, prepare appropriately for possible examination. Waiting until the CFPB alerts you (60 days prior to examination) does not provide enough time for thorough readiness.

A-LIGN provides a third-party assessment of CFPB readiness in three phases:

  • Gap analysis
    • A-LIGN provides a thorough gap analysis for immediate remediation.
  • Remediation assistance
    • Assistance with the rebuilding of controls, policies, procedures and paperwork.
  • CFPB Mock Assessment
    • Know exactly where you stand in terms of preparation for the CFPB assessment.

Would you like to learn more about the CFPB exam preparation and make sure that you’re protected? Contact us today at info@a-lign.com or call 1-888-702-5446

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