I just came across some notes I took during a December 2012 presentation to community bankers by a CFPB employee. Some of his comments were worth sharing...
- We have a wide range of examiners, some fresh out of college. The young ones have book knowledge, not field knowledge. They are committed to the ideals of CFPB.
- You would be surprised at some of the things they will advocate. If you respond affirmatively to their suggestions, you encourage their behavior and they will come up with bigger, better ideas next year.
- You, as seasoned industry professionals, need to push back and explain how things work in the real world. I've told examiners that the folks on the other side of the table have been doing their jobs longer than you have been alive. You have to value their experience.
- We have lawyers on staff, serving as examiners. They were hired not as lawyers, but as examiners. I tell them that! They are not arguing a case before the Supreme Court. They don't need to be litigious.
- We bring enforcement lawyers into exams at the beginning to give thence an understanding of the process. When I was at OCC, they didn't get involved until there was a problem. Then, we had to back up and educate them on the situation. Their presence is not an indication of a problem. They are not meant to intimidate you -- they are there to learn.
- Consumers can tell you every detail of their cell phone data plan (which changes every few years), but don't take any time to try and understand their 30 year mortgage. Sometimes, it's the consumer's fault!
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