CFPB Compliance Documentation Review & Gap Analysis
How we do it
Astra has assessed its own compliance management systems, including its internal controls policies and procedures, for its debt collection business.
Step 1
Is to identify acts or practices that materially increase the risk of violations of Federal consumer financial laws.
Step 2
Is to gather facts that help to determine whether acts or practices violate the requirements of Federal consumer financial laws.
Step 3
Is to take corrective action and implement as appropriate further internal controls, policies and procedures.
A typical CFPB compliance audit addresses applicability to and compliance with the seven (7) modules of the CFPB Examination Procedures (“Examination Procedures”) as listed below:
- Entity Business Model.
- Communications in Connection with Debt Collection.
- Information Sharing, Privacy, and Interactions with Consumer Reporting Agencies.
- Consumer Complaints, Dispute Resolution, and Debt Validation.
- Payment Processing and Account Maintenance.
- Equal Credit Opportunity Act.
- Litigation Practices, Repossession, and Time-Barred Debt.
What we do
Astra’s trained Audit Consultants review our clients' Compliance Management System documentations that focus on these compliance areas and include the following services
- An analysis of provided documents to determine gaps in CFPB compliance documents and those maintained by the agency.
- A review of CFPB compliance documents to gauge compliance with the Examination Procedures requirements.
- A remediation report from Astra detailing any deficiencies requiring correction and/or explanation.
- A review of the agency’s remediation plan and corresponding documents.
In addition to the above-referenced services and scope, Astra offers the following services
- Compliance Document Editing - With agency prior approval and feedback where necessary, Astra will make the necessary changes to the documents provided, so that they meet or exceed minimum expected requirements of the CFPB.
- Compliance Document Drafting -
Upon completion of the above Gap Review, and with agency prior approval and feedback where necessary, Astra will draft compliance documents that BQ Law does not currently have documented.
- CFPB Compliance Manual -
Upon completion of Phase Two and the Audit-Related Services, Astra will create an agency, tab-divided CFPB compliance manual which will include the Astra audit and agency compliance documents.
Records under review are as follows
- Organizational charts and process flowcharts.
- Board minutes, annual reports, or the equivalent to the extent available.
- Notes and disclosures.
- Third-party contracts and oversight materials, including monitoring reports and findings.
- Relevant management reporting.
- Policies and procedures.
- Compensation policies.
- Operating checklists, worksheets, and review documents.
- Monitoring procedures.
- Consumer files, including original loan documents, and payment records systems.
- Historical examination information.
- Audit and compliance reports, and management responses to findings.
- Training programs and materials.
- Scripts for employee use.
- Telephone recordings.
- Written correspondence with consumers.
- Relevant computer program and system details.
- Court documents; and.
- Consumer complaints and disputes, including those submitted to CFPB Consumer Response Center, Consumer Sentinel, the Better Business, CFPB, or other sources as appropriate.
