CBA Comment Letter re CFPB Prioritized Assessments Policies and Procedures

Dear Director Kraninger,


Throughout the novel COVID-19 pandemic, the Consumer Bankers Association (CBA) and our members have worked diligently to protect the financial wellbeing of consumers across the country. Since this unprecedented threat emerged, CBA members have engaged in a host of financial relief and recovery options for customers, aimed at promoting financial safety and security. We plan to continue to serve our customers in every way possible as the effects of this pandemic evolve, and appreciate the work the Bureau has already done to help financial institutions respond to customer needs during this time.


During your comments to the Financial Stability Oversight Council last month, you discussed the Bureau’s new targeted supervisory approach, Prioritized Assessments. You stated Prioritized Assessments will focus on the markets and institutions that pose “the greatest risk of consumer harm as a result of pandemic-related issues.” Since your statement, multiple CBA members have reported receiving notice of a Prioritized Assessment, and many financial institutions seek more information on their scope, timing, and facilitation.


CBA encourages you to release more information about Prioritized Assessment policies and procedures, as well as any updated examination materials or guidance for institutions which would help them better prepare and comply with Bureau requests. Our members stand ready to work with your team to best protect consumers during this time, and increased transparency on the Bureau’s new Prioritized Assessments will greatly help our members better serve customers. Any additional industry guidance on Prioritized Assessments will ensure better protections for consumers during and after this pandemic.


CBA greatly appreciates the Bureau’s efforts during this unprecedented time.  We welcome any opportunity to provide additional assistance or input.  If you have any questions, please contact David Pommerehn, SVP/General Counsel, at 202-207-5161 or at



Richard Hunt

President and CEO

Consumer Bankers Association