On July 26, 2018, the Federal Reserve Board (“FRB”) announced the launch of a new publication called the Consumer Compliance Supervision Bulletin. Similar to the Bureau of Consumer Financial Protection’s (“BCFP”) Supervisory Highlights, the new publication summarizes examiners’ observations from recent supervisory activities and offers guidance on what supervised institutions can do to address consumer compliance risks. The first bulletin focuses on three areas: fair lending, unfair or deceptive acts or practices (“UDAP”), and recent regulatory and policy developments.
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On May 13, The First Marblehead Corporation became the latest in a series of student loan servicers to disclose possible forthcoming enforcement action by the Consumer Financial Protection Bureau (CFPB). While CFPB investigations are generally non-public, First Marblehead’s disclosure and those of other companies that preceded it suggest that the CFPB’s Office of Enforcement has focused on student loan servicing and collection investigations and now has a pipeline of cases close to resolution.  The series of disclosures suggests that 2016 may see as many as four separate enforcement actions focused on student loan servicing.
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