WBK, Clayton Holdings To Begin CFPB Examination Readiness Program

Weiner Brodsky Kider PC (WBK) – a Washington, D.C.-based law firm focused on compliance, regulatory, transactional and litigation legal services – has selected Shelton, Conn.-based Clayton Holdings LLC to assist in WBK's program to help mortgage originators and servicers prepare for Consumer Financial Protection Bureau (CFPB) examinations.

According to the companies, the program is designed to do the following:

– Simulate CFPB examinations of origination and/or servicing operations to measure an institution's ability to detect, prevent and correct practices that may violate CFPB-governed statutes and regulations;
– Identify potential problem areas and assist in devising corrective strategies; and
– Organize and prepare all documents that will be required by the CFPB to accelerate the audit process and mitigate associated costs.

As part of the program, WBK will conduct pre-visit data reviews and analyses with the assistance of Compliance Ease, and Clayton will assist in examining the company's business model, loan files, organizational structure, key documents, and internal policies and procedures.

Past regulatory enforcement actions and consumer complaints will also be reviewed. This will be followed by on-site reviews and interviews with staff members, departmental managers and corporate executives. Program deliverables will include a report drafted by WBK that includes implementation strategies to address process shortcomings and strategies to address possible concerns that may be raised by CFPB examiners.

‘CFPB is on record saying that it intends to step up its examinations and enforcement in 2014,’ comments Mitch Kider, chairman and managing partner at WBK. ‘Our program will help mortgage companies identify and correct issues in advance of CFPB audits."


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