News & Analysis as of

Supervision Consumer Financial Protection Bureau (CFPB) Financial Institutions

Troutman Pepper Locke

The Reversals Continue: CFPB Proposes Rescission of Supervisory Designation Amendments

Troutman Pepper Locke on

On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more

Venable LLP

CFPB Narrows Supervision and Enforcement, Leaving Broader Focus to States

Venable LLP on

The CFPB confirmed in a recent memo to staff that it is shifting its tone on supervision and enforcement—even as reports circulate about significant staffing cuts and potential structural changes at the agency. ...more

Troutman Pepper Locke

The CFPB Issues Revised Sandbox and No-Action Letter Policies

Troutman Pepper Locke on

Earlier this month, the Consumer Financial Protection Bureau (CFPB or Bureau) issued new policy statements regarding its Compliance Assistance Sandbox (CAS) and No-Action Letters (NAL) programs. ...more

Troutman Pepper Locke

CFPB Updates Risk-Based Nonbank Supervision Designation Process

Troutman Pepper Locke on

On Tuesday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule streamlining the designation proceedings for nonbank supervision based on a particular entity posing “risks to consumers.” As...more

Venable LLP

CFPB Updates the Supervisory Appeals Process

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) released a procedural rule updating its supervisory process for institutions seeking to appeal a compliance rating or an adverse finding. Although the appeals process remains...more

Orrick, Herrington & Sutcliffe LLP

CFPB says exam manual and general supervisory findings are nonbinding

On January 9, the CFPB released a blog post, What new supervised institutions need to know about working with the CFPB, discussing what institutions can expect from a supervisory relationship with the Bureau. ...more

Miles & Stockbridge P.C.

“Guidance” is Not the Same as Law: The Role of Supervisory Guidance for Regulated Financial Institutions

“Supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” On September 11, 2018, the Bureau of the Consumer Financial Protection,...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Compliance Bulletin On Confidentiality of Supervisory Information

On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin reminding supervised financial institutions (including large depository institutions, credit unions and their affiliates,...more

Ballard Spahr LLP

Supervisory or Enforcement Action? Deputy Director Explains How the CFPB Decides

Ballard Spahr LLP on

In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more

Ballard Spahr LLP

CFPB issues compliance bulletin on treatment of confidential supervisory information

Ballard Spahr LLP on

In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more

Morrison & Foerster LLP

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

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