United States

RSM creates proactive assessment to prepare collection agencies for CFPB audit


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In February 2012, debt collection agencies were impacted by the newly formed Consumer Financial Protection Bureau (CFPB). At that time, the CFPB ruled that debt collection agencies with more than $10 million in annual receipts would be included in its nonbank supervision program. The program would include, but not be limited to, an annual audit. Although some agencies are subject to federal audits due to high-profile collection contracts with the government, an audit conducted by the CFPB marks a first-of-its-kind process as an agency with rule-making authority over the debt collection industry.


RSM was approached by CBE Companies' (CBE) third-party debt collection business unit, CBE Group, and asked to develop a proactive business assessment. The assessment would allow the company to learn from an unbiased, third-party perspective. RSM and CBE worked together to identify program goals and requirements, as well as to determine areas that would likely be addressed by a future CFPB audit. Then, RSM designed a program that helped CBE prepare for these audits and ongoing federal supervision by the CFPB.

While the new assessment follows the template used by the CFPB when it conducts audits of financial institutions, it was tailored specifically for debt collection agencies. RSM consultants spent one week in both May and June at CBE's corporate headquarters in Cedar Falls, Iowa. There, they interviewed key personnel, reviewed standard operating procedures and ran several tests of systems and processes. RSM's risk assessment focused on the regulations that apply to debt collection agencies, such as the Fair Debt Collection Practices Act (FDCPA) and Fair Credit Reporting Act (FCRA). A final report detailing the findings was delivered to CBE.


RSM's proactive assessment effort ensures CBE continues to deliver on their brand promise and simply do the right thing for consumers and clients. Other benefits the assessment provided include:

  • Ensuring readiness for future CFPB audits
  • Determining whether current policies and operations align with federal guidelines
  • Identifying exposures and potential areas of improvement prior to the audit

Through working with CBE, RSM developed a framework to review other collection agencies that will be subject to federal supervision under the CFPB.

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