The CFPB released its 10th Supervisory Highlights, which focuses on consumer reporting, mortgage origination, fair lending, debt collection, remittances and student loan servicing. The credit union’s compliance and auditing staff should review the report to make sure that the credit union does not end up as a “highlight.” A couple of the highlights include:

Consumer Reporting
The Bureau found that while furnishers had policies and procedures in place pertaining to FCRA furnishing obligations, they failed to have policies and procedures addressing the furnishing of information related to deposit accounts.
Regulation V requires companies that furnish information to consumer reporting companies to establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information they furnish. Whether policies and procedures are reasonable depends on the nature, size, complexity, and scope of each furnisher’s activities.
The Bureau also found that some furnishers of deposit account information failed to correct and update the account information they had furnished to nationwide specialty consumer reporting agencies and did not institute reasonable policies and procedures regarding accuracy, including prompt updating of outdated information.
The FCRA requires furnishers that regularly and in the ordinary course of business furnish information to consumer reporting agencies to promptly update information they determine is incomplete or inaccurate.
Mortgage Origination
The loan originator rule under Regulation Z requires depository institutions to establish and maintain written policies and procedures for loan originator activities, which specifically cover prohibited payments, steering, qualification requirements, and identification requirements. The Bureau found that depository institutions violated this provision by failing to maintain such written policies and procedures.
Bureau examiners concluded that a weak compliance management system allowed violations of Regulations X and Z to occur. For example, supervised entities failed to allocate sufficient resources to ensure compliance with Federal consumer financial law. As a result, these entities were unable to institute timely corrective-action measures, failed to maintain adequate systems, and had insufficient preventive controls to ensure compliance and the correct implementation of established policies and procedures.