Guide to CFPB Mortgage Exams and Enforcement, 2nd Edition

The CFPB doubled the number of mortgage-related exams it conducted in 2015 compared with the prior year and is on track to hold even more exams in 2016. And, because the CFPB doesn't follow a cyclical schedule like the prudential regulators, this force could turn up at your door at any moment.

Learn more about the CFPB’s supervision and examinations—and how you should prepare for and respond to them—in IMF’s Guide to CFPB Mortgage Exams and Enforcement, 2nd Edition. This special report offers tips for supervised entities on what to do before, during and after a CFPB exam. 

For example:

Before: Determine which supervision region you are in. The manner in which exams are conducted and issues are handled can vary from one to another.

During: Pick a member of your staff to serve as primary contact with the CFPB. Make sure this person has enough authority to compel responses and documents from his or her co-workers but enough time to spend his or her days with the examiners.

After: Respond to any PARR letter you receive. It's your opportunity to make your argument against a potential enforcement in a non-confrontational manner.

Partial Table of Contents:

Preparing for an Exam by the CFPB

  • Identifying Risks
  • Compliance Management Systems
  • Opportunities for Corrective Actions
  • Interacting with the CFPB

The Mechanics of a CFPB Exam

  • Responding to CFPB Exam Questions
  • Onsite Space for CFPB Examiners
  • Designated Contacts for CFPB Examiners
  • Responding to Document Requests

Steps After an Exam is Completed

  • Exam Report
  • PARR Letter
  • Action Review Committee Process
  • Subsequent Exams

Trends from Recent CFPB Exams

  • Mortgage-Related Exams
  • Mortgage Servicing Issues
  • Deceptive Practices
  • Problems with Policies and Procedures
  • Positive Practices Cited by the CFPB
  • Loan Originator Compensation Rules
  • Coordinated Exams with State Regulators

Get tips that help you have the best possible exam experience.

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Who "owns" the mortgage customer that’s brought to a wholesale lender through a loan broker?

The broker. It’s his/her client.


The wholesale/table funder. They’re taking the financial risk.


The broker, but only for the first year. After that, the borrower is fair game.


Hard to answer. It’s a complicated issue.