In late January the CFPB announced that Rohit Chopra was being nominated to replace Kathy Kraninger as Director of the CFPB. In the interim between that announcement and today, an Acting Assistant Director, Dave Ueijo, has been appointed. In his memo to the CFPB staff Ueijo made several comments that compliance officers should be aware of because they build on Chopra’s comments and further define the change in the regulatory environment at the CFPB.
- The main vehicle to be used to accomplish Ueijo’s twin goals of helping consumers impacted by COVID and promoting racial equity is to revitalize the division of Consumer Education and External Affairs (CEEA) which is tasked with emphasizing COVID education, racial equality and publishing offenders.
The way the CFPB plans to accomplish these goals is to:
- target resources to help struggling consumers with their delinquencies and foreclosures and student loan debt,
- expand coordination with other agencies to provide more information to homeowners and renters,
- collaborate with consumer advocate groups and
- enhance housing counseling.
In this environment what can banks do?
- ensure your policies and procedures with respect to collection and loan servicing of both student loan debt and mortgage debt are current and acceptable to the regulators,
- make certain your consumer complaint systems are up-to-date and
- analyze your consumer complaints and debt servicing systems to ensure these systems do not reflect disparate treatment.
A word of concern, in none of these comments by the regulators do they mention partnering with financial institutions to solve what problems may exist. To me partnering is a much more effective way to solve problems saving parties time, money and producing more long-lasting answers to issues. Regulators going it alone is scary.