The U.S. responded by shifting many consumer protection responsibilities from existing banking regulators to a newly created agency dedicated to consumer protection. We believe the Consumer Financial Protection Bureau (CFPB), endowed with sweeping new powers and a broad mandate to ensure consistent application of consumer protections across banks and nonbanks, will have a significant impact on the financial services industry.
Promontory has been at the forefront of developments in this area. Retained by some of the largest mortgage servicers in the country, Promontory has been actively engaged in evaluating the foreclosure and loss mitigation practices of these servicers and helping them identify and remediate financial injury to borrowers. This work gives us considerable insight into successful strategies to satisfy new and evolving regulatory expectations for mortgage servicing practices.
Promontory also has extensive experience working with clients and regulators to respond to other regulatory concerns in the consumer area, including enforcement actions related to fair lending, as well as unfair and deceptive acts and practices. Our experts’ regulatory backgrounds give them unique knowledge and understanding of the expectations of the regulatory agencies, including the CFPB. We expect the CFPB to vigorously pursue enforcement and examination, including abusive acts or practices. For nonbanks unfamiliar with examination by a federal regulator, the CFPB’s examination authority will pose unfamiliar challenges. Promontory has worked with many nonbanks in the past to prepare them for federal regulatory scrutiny, including conducting mock examinations led by former federal regulators.