CFPB: Monitoring Elder Abuse

The CFPB has named former Minnesota attorney general and state senator Hubert H. Humphrey III as the head of its newly established Office of Older Americans.

In a conference call Oct. 19, 2011, Humphrey said the most important priority for the new office will be to "listen, to hear from our seniors so that we learn and understand exactly what they are facing." Despite the absence of a confirmed CFPB director, Humphrey said "we have a lot of work to do right now that we can take on."

Humphrey noted that Americans over the age of 62 have been particularly hard-hit by the past few years, making it hard for them to pay bills or to enjoy retirement. Seniors are losing an estimated $2.9 billion a year to financial abuse, he said, while housing values have dropped 30 percent nationally since their peak in 2006.

The CFPB said the various tasks of the Office of Older Americans will include educating seniors about their financial choices in the areas of long-term savings, retirement planning and long-term care. It will also provide coordination between senior groups, law enforcement, financial institutions and federal and state agencies to identify and prevent scams.

House Financial Services Committee Ranking Member Barney Frank, D-Mass., praised the choice of Humphrey, noting that attorneys general have been at the forefront of consumer protection. "One of the goals in establishing the CFPB was to create, at the federal level, a capacity and willingness to defend consumers that has long been present in the states but not nationally," he said.

Rep. Carolyn Maloney, D-N.Y., a senior member of the House Financial Services Committee, also hailed the appointment, stating that Humphrey's "commitment to consumer protection as Minnesota's Attorney General, along with his breadth of experience as Minnesota State President of the American Association of Retired Persons and one of their national board members will serve the CFPB exceptionally well."

For information about the Office of Older Americans and resources to help older Americans and their families, visit: www.consumerfinance.gov/older-americans. 

Library

Consumer Financial Protection Bureau

Hubert H. Humphrey III appointed to administer
the Office of Older Americans

Full Text
October 19, 2011

CFPB: Presentation on Consumer Complaints Portal

On July 21, 2011, the CFPB recently developed a special access portal that allows financial institutions to view and respond to complaints in the CFPB consumer complaint database.

Recently, the CFPB provided a presentation describing the consumer complaint portal, relevant information regarding its use, and FAQs. The presentation is accurate as of September 20, 2011.

At this time, the portal takes consumer complaints about credit cards and provider resources for distressed homeowners. This portal allows complainants to check the status of their complaints.

The portal is meant to serve as a liaison between the CFPB and financial institutions. After receiving a complaint and addressing the complaint directly with the consumer, financial institutions can use the portal to provide an explanation of the resolution and the actions taken, select a resolution status, and attach relevant documents if necessary.

The Presentation is available in our Library.

Company Portal Manual

The CFPB calls the consumer complaint portal's presentation the "Company Portal Manual." Essentially, the Company Portal is designed to enable financial institutions to view and respond to complaints submitted to the CFPB by consumers.

In using the portal, financial institutions are able to provide an explanation of the resolution and the actions taken with respect to the consumer compliant.

Additionally, financial institutions will provide a status for the complaint and may actually attach relevant, supporting documentation with respect to the resolution.

Selecting the Status   

The CFPB asks that financial institutions respond to a consumer complaint within 10 days of the filing date.

There are four possible statuses that may be selected by the financial institution: Full Resolution Provided, Partial Resolution Provided, No Resolution Provided, and Incorrect Company.

LIBRARY

 

Consumer Financial Protection Bureau

Company Portal Manual
Consumer Complaints

September 20, 2011

CFPB Issues Mortgage Disclosure Update

The CFPB has issued its fourth update to the Mortgage Disclosure form. This is the fourth time since May 2011 that the CFPB has issued an update to the form and requested comments. 

To date, the CFPB has received more than 24,000 comments, as part of its Know Before You Owe, the review program that commenced in May 2011. The CFPB website, activated on February 3, 2011, contains more information about providing feedback to the Know Before You Owe endeavor.

In September, the CFPB requested that commenters compare two different designs as well as to compare two different loans using the same design. The purpose of the comparative approach is apparently to enable the public to determine ease of use.

We have reported continuously on the development of the Mortgage Disclosure, for example, here and here.

At this time, the CFPB has also undertaken a study to update the HUD-1 Settlement Statement. When that model is introduced, the CFPB will again ask for comments.

Fourth Model 

This fourth model is being tested with consumers and industry in Albuquerque, New Mexico. In that study, the CFPB is comparing a fixed-rate and an adjustable-rate loan, permitting the users to see how this prototype would work for both loan products.

Essentially, the model is based on a disclosure that combines the Truth in Lending form and the Good Faith Estimate.

Interesting Comments  

There have been various comments of interest to the development of the Mortgage Disclosure. Among the more interesting are: suggesting that the cost calculations show a 10 year time frame, to clearly distinguish separately the lender from the non-lender charges, to add more information about shopping for mortgages, and to more clearly explain the time-sensitivity of price comparisons. 

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    Consumer Financial Protection Bureau     

Mortgage Disclosures - Models
Fixed and Adjustable  
October 17, 2011

CFPB Issues Supervision and Examination Manual

On October 13, 2011, the Consumer Financial Protection Bureau (CFPB) issued its Supervision and Examination Manual - Version 1.0 (Manual). This is first edition of a guide devoted to how the CFPB will supervise and examine consumer financial service providers under its jurisdiction for compliance with Federal consumer financial law.

The Manual is divided into three parts: 

Part 1: Describes the supervision and examination process. 

Part 2: Contains examination procedures, including both the general instructions and the procedures for determining compliance with specific regulations. 

Part 3: Provides templates for documenting information related to supervised entities and the examination process, including examination reports.

Unfortunately, at this time Part 1 and Part 2 are only available as website pages. Part 3 is available in PDF.

However, we have created a Directory and Compendium.

At this time, Part 1 and Part 2 are only available as website pages.

Part 3 is available in PDF.

In preparing our Audit and Due Diligence procedures for our clients, we have combined all three parts into a single Directory with links to both each section's text and website links. There are over 700 pages in this compendium. 

Our compendium provides:

• Directory: All Sections
• Contents: Links to Compendium Text
• Contents: Links to CFPB Website Text

We are pleased to share this compilation with you for free.

Due to the huge size of the compendium - over 13 MBs - it must be downloaded from our secure Extranet. If you are interested in obtaining this compendium, please request it and we'll send you the download instructions.

Supervision and Examination Manual - Version 1.0 

OUTLINE

Part I - Compliance Supervision and Examination

Supervision and Examination Process     

Overview     

Examinations 

Part II - Examinations Procedures 

Compliance Management Review

Unfair, Deceptive or Abusive Acts or Practices     

Narrative     

Examination Procedures

Equal Credit Opportunity Act     

Narrative     

Examination Program     

Interagency Fair Lending Examination Procedures     

Interagency Fair Lending Examination Procedures – Appendix

Home Mortgage Disclosure Act     

Narrative     

Examination Procedures     

Home Mortgage Disclosure Act Checklist

Truth in Lending Act     

Narrative     

Examination Procedures     

Appendix A: High-Cost Mortgage (§ 226.32) Worksheet

Real Estate Settlement Procedures Act     

Narrative     

Examination Procedures     

Checklist 

Homeowners Protection Act     

Narrative     

Examination Procedures

Consumer Leasing Act     

Narrative     

Consumer Leasing Act Examination Procedures     

Consumer Leasing Act Checklist

Fair Credit Reporting Act     

Narrative     

Examination Procedures

Fair Debt Collection Practices Act     

Narrative     

Examination Procedures

Electronic Fund Transfer Act     

Narrative     

Examination Procedures     

Checklist 

Truth in Savings Act     

Narrative     

Examination Procedures     

Checklist

Privacy of Consumer Financial Information (GLBA)     

Narrative     

Examination Procedures     

Examination Procedures Attachment     

Checklist

Mortgage Servicing Examination Procedures 

Part III - Examination Process Templates     

Templates     

Entity Profile     

Risk Assessment     

Supervision Plan     

Examination Scope Summary     

Examination Report     

Examination Report cover     

Examination Report cover letter

LIBRARY

Consumer Financial Protection Bureau

Supervision and Examination Manual 

Version 1.0 

Announcement

October 13, 2011