WBK Industry - Federal Regulatory Developments

CFPB Expands Its Examination Manual to Include a New Section on IT

The CFPB has recently added to its Examination Manual a new section, “Compliance Management Review – Information Technology”.  This new section is part of the Compliance Management System review. 

The CMS-IT examination manual contains five Modules as follows:  

  • Module 1: Board and Management Oversight
  • Module 2: Compliance Program
  • Module 3: Service Provider Oversight
  • Module 4: Violations of Law and Consumer Harm
  • Module 5: Examiner Conclusions and Wrap-Up

In the summary of this new section, the CFPB now makes the evaluation of an institution’s technology controls and its service providers part of the overall CMS assessment.