Preparing for CFPB Compliance: A Credit Union Success Story
- TOPICS:
- Regulatory Compliance
- Assessment
Bridgeforce’s regulatory assessment helps a credit union understand the strength of their operating procedures and areas of needed improvement to be ready for an eventual CFPB Compliance Examination.
A top-10 credit union recently achieved $10 in assets, placing them in the scope of CFPB supervision. However, they lacked insight on their readiness for a CFPB exam. Client stakeholders requested external help to determine where improvement was needed in their Collections, Contact Center, 2nd Line of Defense, and Internal Audit business areas.
Bridgeforce shed light on the processes that were sufficient for an exam and where and how critical enhancements could be made for adequate readiness in all business areas. The client had a confident gameplan to become CFPB-ready.
Proprietary Assessment Matrix Measures Processes Against CFPB Compliance Expectations
Bridgeforce‘s wheelhouse includes a comprehensive assessment matrix, sourced from CFPB examination manuals, relevant regulations, and recent enforcement actions. Our proprietary matrix outlines 197 distinct readiness criteria expected of the credit union.
Using the matrix, the team reviewed nearly 300 client documents and conducted a series of interviews to understand their current state of operations.
Recommendations for Enhancements
The final part of the matrix outlined recommendations for future enhancements. A detailed roadmap showed the client how to implement a total of 186 recommendations, allowing the client to understand priorities and the work effort required for execution.
These enhancements were prioritized by importance and execution level of effort to provide a sequenced approach to address observations.
For example, Bridgeforce discovered that the client’s vendor management program was underdeveloped. They needed to demonstrate that their third-party service providers are complying with Federal consumer financial laws. Bridgeforce recommended specific vendor requirements for ongoing monitoring.
Ready for the Eventual CFPB Examination
At the end of the project, the client fully understood their readiness for an assessment. Our recommendations explained exactly how the credit union could fix remaining compliance gaps to be confident for their first CFPB exam.
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