An agreement two years ago between federal and state regulators to coordinate supervision of companies that provide consumer financial products and services took a step forward this week.
A memorandum of understanding was executed in January 2011 by the Consumer Financial Protection Bureau and the Conference of State Bank Supervisors.
The conference says it is “the nation’s leading advocate for the state banking system, and the only national organization dedicated to advancing the state banking system.”
At the time, the regulators said they would work to maintain consistent examination procedures, create effective enforcement of state and federal consumer laws and minimize regulatory burden. The CFPB said it would consult with the states about their standards, procedures and practices on compliance examinations.
The CFPB is required by the Dodd-Frank Wall Street Reform and Consumer Protection Act to coordinate supervisory activities with state bank regulators.
On Tuesday, the CFPB announced that it had established a framework with which to work with its state counterparts. The framework facilitates the implementation of the Dodd-Frank act requirement “by providing a guide for flexible and dynamic regulatory coordination that both protects consumers and reduces regulatory burden on industry.”
The framework establishes a process for coordination on supervision and enforcement and impacts situations where the CFPB and state regulators share concurrent supervisory jurisdiction.
Processes for annually coordinating exam schedules and information requests, developing comprehensive supervisory plans for particular institutions and streamlining information sharing are all addressed by the framework. It also addresses processes for providing advance notice of corrective actions.
All non-depository institutions, as well as depository institutions with more than $10 billion in assets, are subject to the framework — though a majority of the examinations covered by the framework are those on large, multi-state entities.
“By working together, we are streamlining our processes, making the most of our joint resources, and ensuring evenhanded oversight of federal consumer financial laws,” CFPB Director Richard Cordray said in the statement.
However, the CFPB and state regulators will continue to independently conduct examinations that are outside the intended scope of the framework.
