The Consumer Financial Protection Bureau (“CFPB”) entered into a memorandum of understanding (“MOU“) with the Conference of State Bank Supervisors (“CSBS”) whereby the CFPB and CSBS agreed to work cooperatively on oversight of providers of consumer financial products and services such as mortgage loans, private student loans, payday loans and other consumer financial services. The MOU provides that the CFPB and CSBS will work closely together to: (1) promote consistent examination procedures; (2) coordinate supervisory activities, (3) promote efficient information sharing; (4) enforce federal and state consumer protection laws; and (5) minimize the regulatory burden on providers of consumer financial services and products. The MOU also states that the CFPB and the CSBS will consult on exchanging information regarding, and/or jointly developing, training programs for examiners concerning the standards, procedures and practices used by the CFPB and CSBS. The MOU also addresses the need to ensure maintaining the confidentiality of information that is exchanged under the MOU. It is expected that the focus (at least initially) of the CFPB and CSBS with respect to the MOU will be on non‑depository financial institutions.
Alert January 11, 2011