About six months ago, Mick Mulvaney took over as acting director of the Consumer Financial Protection Bureau, and has received criticism for his actions, and lack thereof, while leading the bureau.
So what exactly does a CFPB exam look like under today’s standards, and what can lenders expect from exams under Mulvaney’s bureau? One lender gave the inside scoop in a panel Thursday at the NEXT Women’s Mortgage Tech conference in Dallas.
During the panel, one major lender gave attendees an inside look at the company’s recent CFPB audit.
They explained some key points to help prepare:
Get executive management involved: The lender explained that the earlier executive management is brought in on the exam prep, the better it will be for the company. While some managers tend to leave the preparation to the compliance department, the company will experience better results when management is engaged in the process.
Create PowerPoints: PowerPoints will keep the focus on the exam where the company wants it. It gives the company more control of the direction of the discussion. While CFPB examiners will still ask questions, often times it will be directed at the information coming from the slides. They explained the more extensive the power points are and the more information they hold, the better.
However, soon thereafter, Mulvaney’s “kinder, gentler” memo was released. But the company’s CFPB area manager said this wouldn’t change anything, and the exam would still go on as planned.
The next doubt surfaced when the Washington Post published an article announcing President Donald Trump was stripping lending enforcement powers from the Office of Fair Lending. However, once again the company was told that while enforcement action was being moved to another department and there could be personnel changes, CFPB examinations would continue as before.
But the next day, the company was informed that the head of the Office of Fair Lending would not, in fact, be attending the exam.
First, as there were and continue to be several personnel shifts, the new CFPB examiners are typically less experienced and do not always know many specifics about the mortgage industry.
Also, while the CFPB exams may look similar to the way they did before, there will certainly be fewer exams performed.
