Alert January 10, 2013

CFPB Releases Private Student Loan Examination Manual

The CFPB published its Student Lending Examination Procedures.  The procedures include guidance for examination of all aspects of private education loans and for examination of the servicing of legacy Family Federal Education Loan Program loans. The Examination Procedures contain the following seven modules, which may be used in various combinations during examinations: (1) advertising, marketing, and lead generation; (2) customer application, qualification, loan origination and disbursement; (3) loan repayment, account maintenance, payoff processing and payment plans; (4) customer inquiries and complaints; (5) collections, accounts in default and credit reporting; (6) information sharing and privacy; and (7) examination conclusion and wrap-up (required in all examinations).