The Consumer Financial Protection Bureau (CFPB) recently announced its new mandatory TILA and ECOA examination procedures to evaluate lender compliance. What is most evident in both of these new procedures is the need for lenders to have a sound compliance management system (CMS) as part of the compliance program. It is no secret that the CFPB considers a CMS a key component of a well-functioning compliance program and it has already been an area of focus for regulators. . ” Yes, the world has officially changed for lenders. Not only is a compliance management system critical to a lender’s continued success, but it is also the law. Lenders must ensure their compliance management system is sufficient to meet the new CFPB standards.
The CFPB is primarily concerned with institutions’ compliance infrastructure: the ability to detect compliance problems and initiate prompt corrective actions. To determine this, auditors will interview management and examine organizational charts to determine whether the financial institution’s internal controls are adequate to ensure compliance.
Poor audit findings can result in fines and increased future scrutiny, while also damaging existing and future business relationships. Does your financial institution have a proper compliance management system in place?
If you have questions about our blog, “Consumer Financial Protection Bureau Mandates Lender Compliance Procedures,” or your institution’s current compliance management system, please contact Offit Kurman labor and employment attorney Ari Karen at email@example.com. Ari has counseled many mortgage banks and financial services firms on the development and implementation of policies and procedures related to allowing institutions to remain compliant with wage hour laws and other labor and employment regulations.
Offit Kurman Attorneys at Law: Financial Institutions Compliance Practice Group
At Offit Kurman Attorneys At Law, the attorneys in our Financial Institutions Compliance Practice Group offer legal representation and counseling for commercial and corporate transactions, regulatory compliance, government enforcement, public policy and governmental affairs and litigation and arbitration.
If you would like to learn more about Offit Kurman’s Financial Institutions Compliance Practice Group to see what we can do for you, please fill out our contact form to access the knowledgeable legal guidance that our experienced team of attorneys has to offer. Offit Kurman is a dynamic legal services provider assisting clients throughout the mid-Atlantic region. Our firm is well positioned to meet the legal needs of dynamic businesses and the people who own and operate them.
CFPB Officially Mandates Compliance Infrastructure National Mortgage News