When it comes to the Consumer Financial Protection Bureau's
("CFPB" or the "Bureau") compliance
expectations, it is important to separate myth from fact.
These days, the CFPB is moving full-steam ahead on examining
non-banks and banks, dozens at a time, and is not leaving any stone
unturned for potential unfair, deceptive or abusive acts or
practices in violation of the Consumer Financial Protection Act or
other consumer financial laws that fall under its
scope.
Myth #1: Only large financial institutions
are subject to CFPB supervision and examination.
No provider of consumer financial products and services, or their
service providers, should assume they are beyond the reach of the
CFPB. The CFPB can examine any entity, regardless of size,
based on regulatory authority to supervise "risky"
financial products and services that it believes are causing harm
to consumers. This authority is in addition to the CFPB's
ability to supervise larger market participants
