Consumer Financial Protection Bureau (CFPB) Working Group

The CFPB Working Group is Chaired by Kurt Steinmiller. If you would like to be a part of the group, please email Kurt.

Background

The Consumer Financial Protection Bureau (CFPB) was created upon passage of the Dodd Frank Wall Street Reform and Consumer Protection Act in July of 2010. Charged with supervision of all consumer financial products and to protect consumers from unfair, deceptive, and abusive financial practices, the purpose of the CFPB was to consolidate consumer protection under a single independent agency and eliminate the previous scattered approach.

All if not most COHEAO members are impacted by decisions made by the CFPB. A rule was published by the CFPB on October 24, 2012, announcing that the agency would supervise the larger consumer debt collectors and published the examination guide that the agency would use as they audited these entities. COHEAO’s membership roster includes these third-party debt collection companies who contract with colleges/universities to provide services.

The CFPB issued oversight rules on December 3, 2013, that would permit the agency to supervise certain nonbank student loan servicers. Once again, COHEAO’s membership rolls include student loan servicers who provide billing products for colleges/universities.

An announcement was published by the CFPB on January 20,2022 that the agency intended to examine the operations of post-secondary schools that would include evaluating their institutional loan programs, transcript withholding policies and other practices. The majority of COHEAO’S membership consist of colleges/universities and some of these members may be impacted by this announcement.

COHEAO CFPB Task Force Objectives

The CFPB rules and regulations influence the operational processes for most COHEAO members. In response, the Task Force is charged with the responsibility to provide updates to the organization’s Board of Directors on any regulatory or legislative activity that may impact any members. In addition, the Task Force assists Agenda Committee on an as needed basis to locate subject experts for webinars, and conference presentations.

COHEAO’S Task Force also monitors for opportunities to provide responses upon publication of any CFPB solicitation for comments and/or proposed rulemaking.

COHEAO’s CFPB Working Group has published two papers on the Bureau.  They are listed below:

CFPB Website

https://www.consumerfinance.gov/

  • CFPB- Fair Debt Collection Practice Act (Includes Reg F updates)

                                https://www.consumerfinance.gov/rules-policy/regulations/1006/versions/1/

Recent News

  • CFPB Education Loan Examination Procedures (Updated September 2022)

                                https://www.consumerfinance.gov/compliance/supervision-examinations/education-loan-examination-procedures/

  • CFPB Supervisory Highlights-student Loan Servicing (Fall 2022)

https://files.consumerfinance.gov/f/documents/cfpb_student-loan-servicing-supervisory-highlights-special-edition_report_2022-09.pdf