On November 3, 2015, the Consumer Financial Protection Bureau (CFPB) posted on its website a written policy implementing a supervisory appeals process (click here) if a supervised entity disagrees with (i) a less than satisfactory compliance rating, (ii) an adverse finding in an examination report, or (iii) an adverse finding in a supervisory letter. In addition to the above, the key aspects of the appeals process in the policy are: • CFPB managers who did not participate in the supervisory matter and whose knowledge and background enable them to meaningfully evaluate supervisory matters will be involved in reviewing appeals.
