by Rachel Rodman, Robert Duncan, and Scott Cammarn
On July 16, 2020, the Consumer Financial Protection Bureau (“CFPB”) hosted a webinar outlining, for the first time, the CFPB’s supervisory and enforcement priorities in light of the coronavirus pandemic. Of note, the CFPB announced that it has de-prioritized a good portion of the agency’s existing exam schedule to conduct “prioritized assessments” focused on (i) consumers having trouble making loan payments, and (ii) markets where Congress provided special borrower protections under the CARES Act. These include: residential mortgage servicing, student loan servicing, auto loan servicing, consumer reporting and furnishing, and collections. The CFPB also stated that it plans to assess financial institutions’ implementation of the Paycheck Protection Program (“PPP”) for fair lending compliance. We expect these prioritized assessments will be the leading edge of the CFPB’s supervisory and enforcement work in consumer financial services markets most impacted by the pandemic.