What the Consumer Financial Protection Bureau ... - Venable LLP

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CFPB: PREPARING FOR SUPERVISIONAND EXAMINATIONAreas of Focus by the CFPB related to PrivateEducational Loans*•Unfair, Deceptive andAbusive Acts and Practices•Equal Credit OpportunityAct (ECOA) and Regulation•Truth in Lending Act•Electronic Fund TransferAct (15 U.S.C. 1693 et seq.)•Fair Credit Reporting Act(15 U.S.C. 1681et seq.)•Fair Debt CollectionPractices Act (15 U.S.C.1692 et seq.)•Gramm-Leach-Bliley Act of2009•Internal Revenue Code*(may report to the IRS)•State Statutory andRegulatory Requirements(may report to state AGs)* non-exhaustive list29
WHAT’S HAPPENING AT THE CFPB ONNONBANK SUPERVISION?• Dodd-Frank Supervision Authority – Under the law, theCFPB has authority to oversee nonbanks, regardless ofsize, in certain specific markets, including privateeducation lenders and their service providers ...• Supervision and Examination Manual• Attorney-Client Privilege and Attorney Work ProductConsiderations—CFPB Rulemaking Efforts
Page 1 and 2: What the Consumer FinancialProtecti
Page 3 and 4: AGENDA• Introduction• The Dodd-
Page 5 and 6: WHAT’S THE COST OF NONCOMPLIANCE?
Page 7 and 8: WHERE DOES THE CFPB FIT IN WITH OTH
Page 9 and 10: DODD-FRANK ACT - HOW WE GOT HERE…
Page 11 and 12: CFPB: OVERVIEW AND STRUCTURE
Page 13 and 14: CFPB: OVERVIEW AND STRUCTURECFPB FO
Page 15 and 16: CFPB: OVERVIEW AND STRUCTURECFPB St
Page 17 and 18: CFPB: FOCUS ON PRIVATE STUDENT LOAN
Page 19 and 20: PRIVATE STUDENT LOAN OMBUDSMAN•Pr
Page 21 and 22: CFPB: FOCUS ON STUDENTS• White Ho
Page 23 and 24: CFPB: FOCUS ON STUDENTSStudent Debt
Page 25 and 26: CFPB SERVICEMEMBER AND VETERANINITI
Page 27: CFPB: Preparing for Supervisionand
Page 31 and 32: SUPERVISION PROCESS PRINCIPLES• C
Page 33 and 34: CFPB SUPERVISION ANDEXAMINATION MAN
Page 35 and 36: CFPB ENFORCEMENT AUTHORITY• CFPB
Page 37 and 38: CFPB REFERRALS FROM EXAMS• Crimin
Page 39 and 40: WHAT WILL THE CFPB BE LOOKINGFOR?
Page 41 and 42: UNFAIR ACTS AND PRACTICESDEFINEDThe
Page 43 and 44: ABUSIVE ACTS OR PRACTICESDEFINED•
Page 45 and 46: CFPB: NAVIGATING INVESTIGATIONSAND
Page 47 and 48: EARLY WARNING NOTICE OFPOTENTIAL EN
Page 49 and 50: KEY STEPS TO RESPONDING TO ANINVEST
Page 51 and 52: KEY STEPS TO RESPONDING TO ANINVEST
Page 53 and 54: CFPB AND SERVICE PROVIDERS TOCOVERE
Page 55 and 56: WHAT’S NEXT AT THE CFPB ANDPRIVAT
Page 57 and 58: MAY 2012

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