By Katalina M. Bianco, J.D.
Steven Antonakes, Deputy Director of the Consumer Financial Protection Bureau, offered a peek into the CFPB's thought processes on supervision in prepared remarks before the The Exchequer Club in Washington, D.C. CFPB supervision made simple? Perhaps not, but Antonakes did shed some light on factors the bureau takes into consideration when it comes to supervision.
Antonakes, who leads the Division of Supervision, Enforcement, and Fair Lending, laid out for club members the institutions under CFPB supervision and described how the bureau prioritizes its supervisory responsibilities. The bureau breaks down institutions by product line, he said. Each product line is evaluated on: potential for consumer harm related to a particular market; the size of the product market; the entity's market share; and risks inherent to the institution's operations and the consumer financial products offered.
The bureau considers field and market intelligence, which includes both qualitative and quantitative factors for each institutional product line, such as the strength of compliance management systems, the existence of other regulatory actions, findings from prior exams, metrics gathered from public reports, and the number and severity of consumer complaints, Antonakes explained. Finally, the CFPB supplements general field and market intelligence with fair-lending-focused information to ensure that it appropriately identifies and prioritizes fair lending risks.
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