Yesterday, the Consumer Financial Protection Bureau (CFPB) released its Fall Supervisory Highlights. The report covers examinations completed between January and June of 2021. Over the last year, the Biden-era CFPB has made various statements about its priorities. For instance, the Bureau has issued comments or taken action related to the small dollar lending agenda, auto finance, fintechs and technology companies, mortgage discrimination, and small business lending. The CFPB has been particularly vocal about COVID-19 issues, going so far as to publish a special edition of its Supervisory Highlights in January focusing entirely on issues related to the pandemic. However, the Bureau’s Fall Supervisory Highlights provide a more comprehensive picture of where the Chopra-led CFPB has expended effort and resources, and where industry stakeholders can expect continued scrutiny in the months and years ahead.
In particular, the Fall Supervisory Highlights cover a broad swath of issues, including fair lending, mortgage servicing, debt collection, small dollar and payday lending, student loan servicing, and credit card account management, among other items. Unsurprisingly, the Bureau continues to take a hard look at alleged legal violations arising out of the COVID-19 pandemic. According to CFPB Director Rohit Chopra, the report “reveals that irresponsible or mismanaged firms harmed Americans during the COVID-19 pandemic.” Consistent with the CFPB’s recently emphasized focus on fair lending issues, the report also identifies widespread purported fair lending violations in both the consumer and business finance spaces. The Bureau specifically stated that it is “committed to rooting out all forms of lending discrimination, including redlining.”
In total, the Fall Supervisory Highlights contain a detailed explanation of the CFPB’s findings that promise to shed light on how this version of the Bureau will flex its supervisory muscle. As such, each section of the report deserves its own detailed treatment. Over the next few weeks, Bradley Financial Services attorneys will publish detailed coverage of each of the Supervisory Highlights’ findings in this space in order to provide greater insight into the pulse of the Bureau. Stay tuned!
Update: Blog Posts in this Series
Future blog posts on these topics will be posted below. Please check back for updates.
- Our follow up analysis on Small Dollar Lending has been published on December 22, 2021: CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Small Dollar Lending
- Our follow up analysis on Mortgage Servicing Loss Mitigation Violations has been published on January 5, 2022: CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Mortgage Servicing Loss Mitigation Violations
- Our follow up analysis on Fair Lending has been published on January 24, 2022: CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Fair Lending