Dan Soto, chief compliance officer for Ally Financial Inc. asked attendees at the American Financial Services Association’s 19th annual Vehicle Finance Conference how prepared their companies were for the Consumer Financial Protection Bureau: over half – 56% – answered ‘Somewhat.’
Soto also asked how many attendees knew that their companies were in full compliance with every rule, from every regulatory agency – state, federal, and international: no hands were raised.
Often lenders feel like the CFPB can be more prosecutory than regulatory, Soto said, but it is something that the industry will have to continue to deal with in the New Year.
Be prepared for a CFPB examination, he advised, and know what is expected of you at every stage, be transparent, don’t hide anything. Soto said that some companies argue that in the past they told the CFPB everything and the bureau used it against them. “Imagine how bad it would be if you didn’t,” he asked.
If an agency wants to look at files, find out what format and make them all look the same. If things are in shambles, Soto told the audience, the examiners will just stay longer.
Soto also predicted that vendor management will be a focus in 2015, now that companies are out-sourcing more than ever. Third party vendors are no longer “our fingers and toes,” he said, companies depend on them, but they must be managed.
Soto ended his presentation by reminding attendees that in the past, when he would speak about compliance management at AFSA, or similar, events, people would roll their eyes. “You’re not doing that today,” he said.