CFPB Revises Supervisory Appeals Process

What Happened

On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a procedural rule revising its supervisory appeals process for the first time since 2015. This Rule makes several important changes:

1. Under the Rule, any CFPB manager who did not participate in the underlying supervisory matter and who is familiar with the topic may be assigned to a supervisory appeals committee, rather than only managers in the Supervision division, as had been the case previously. The Supervision Director will select three managers to serve on the appeals committee, which will, in turn, advise the Supervision Director on the appropriate resolution of the appeal. Legal counsel designated by the General Counsel will advise the committee as needed.