Recent CFPB Examinations Relating to COVID-19: Impacts and Accommodations

Over the past couple of weeks, the CFPB began sending “pandemic-related” supervisory examination notices to companies across the consumer financial services industry. The CFPB seeks information about how recipients have altered their lending, servicing, furnishing, and collection practices as a result of COVID-19. Members of the private student loan, auto lending, and debt collection and purchasing industries all are among those who already are being examined, and the CFPB has made clear it intends to look at specific COVID-19 issues in mortgage servicer exams. The CFPB’s information requests ask for information and data relating to how these companies have been impacted in their:

• ability to service accounts,
• resolution of consumer complaints and disputes,
• communication of accommodation options,
• processing of payments,
• compliance with state-specific requirements, and
• incorporation of accommodation codes into their credit reporting

Join our discussion to learn more about these recent examinations, how they differ from examinations of the past, what they may indicate for the future and what steps you should be taking now to prepare for these examinations.