The Consumer Financial Protection Bureau (CFPB) issued the Fall 2021 edition of its Supervisory Highlights report. This edition covers examination topics the CFPB identified between January and June of 2021. Areas of focus in this edition include:

  • Credit card billing errors and deceptive marketing of credit card bonus offers.
  • Falsely representing the impact to consumer creditworthiness during debt collections process.
  • Investigation and error resolution of misdirected EFT payments.
  • Lending discrimination using pricing exceptions and considerations based on borrower’s religion.
  • Mortgage Servicing, including:
    • Charging of delinquency fees to borrowers in CARES Act forbearances.
    • Failing to terminate pre-authorized EFT’s.
    • Charging unauthorized amounts in connection with service provider fees.
    • Misrepresenting transaction and payment history in online account portals.
    • Failing to evaluate complete loss mitigation applications in a timely manner.
    • Incorrect handling of partial payments.
    • Failing to automatically terminate PMI.
  • Payday lending loan extensions, erroneous debiting, and failing to retain records.
  • Stop-payment violations on pre-paid accounts.
  • Failing to timely investigate after receiving notice of errors in remittance transfers.

Also, the report announces that the temporary supervisory and enforcement flexibility of mortgage servicing timing requirements (announced in the April 2020 Joint Statement) will no longer apply. Going forward, agencies will apply their supervisory and enforcement authority to address noncompliance with Regulation X mortgage servicing rules when appropriate.

Supervisory Highlights