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FOS Blog

10 Dec

Establishing a Compliance Management System

Establishing a Compliance Management System
Impact of the CFPB

The Dodd-Frank Act gave the CFPB supervisory and examination authority over collection agencies, debt buyers and collection attorneys, as well as, Banks and other members of the financial services industry.  The CFPB promulgated the Larger Market Participant rule for debt collectors, which defined industry members with annual receipts resulting from consumer debt collections of more that $10 million as a larger market participants subject to examination and supervision.

Even if your agency does not meet the larger market participant threshold, the CFPB can examine your company. For example, service providers of supervised entities (e.g. collections services provider of larger banks) including larger market participants may be subject to CFPB examination. In addition, the CFPB has declared that it can and will examine any company who it believes is causing consumers harm. So regardless of your company’s size the CFPB can supervise and examine your entity.

The CFPB’s priorities focus on the compliance management system that your organization maintains.  What is a compliance management system? The compliance management system should:

  • Establish your compliance responsibilities
  • Communicates those responsibilities to your employees
  • Ensure that the responsibilities for meeting legal requirements and internal policies are incorporated into business processes
  • Review operations to ensure responsibilities are carried out and legal requirements are met
  • Take corrective action and updates tools, systems and materials as necessary.

The CFPB’s compliance management priorities include policies and procedures, training, monitoring and corrective action, consumer complaint response and compliance audit.

Reach out to our compliance professionals to assist in comparing your compliance management system with the CFPB’s priorities. For additional information regarding this article contact the author Debbi Fetter at

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