The CFPB Supervision Style Guide (May 2014) (Highlighted Updates)

The CFPB Supervision Style Guide
How to Use this Guide

This guide is a reference tool for supervision staff who write supervisory documents such as
information requests, examination reports, and supervisory letters. The guide reflects the
CFPB’s voice and style guidelines. All CFPB employees have an investment in the CFPB’s
credibility and public image. This Guide will help ensure the integrity and quality of our
communications with supervised providers of financial products and services to consumers. A
consistent voice and style will also make the process of drafting documents easier. Comments,
suggestions, and questions should be sent to: CFPB_Supv_Staff_Input@cfpb.gov
About the Style Guide
NOTE: Updates to the Style Guide are highlighted in yellow.
The Style Guide is broken down into several:

Page
I. Preferred Usage of Common Words and Phrases (A – Z) 2
II. Preferred Punctuation and Formatting (A – Z) 23
III. Preferred Terminology in CFPB Supervision Documents (A – Z) 31
IV. Referencing Statutes and Regulations 34
V. Frequently Referenced CFPB Offices 40
VI. Preferred Usage of State Abbreviations 41
VII. Preferred Usage of Major City Names 42
VIII. Frequently Referenced Federal Agencies 43
IX. Preferred Style: Matters Requiring Attention 44
X. Preferred Style: Violations 54
The CFPB Supervision Guide is based on the CFPB’s Style Guide

(http://team.cfpb.local/wiki/index.php/CFPB_Voice_and_Style_Guide).
The Supervision Style Guide differs from the CFPB’s Style Guide in some respects. In these
cases, the CFPB Supervision Style Guide prevails. When faced with a style question, first
consult the Supervision Style Guide. If the answer is not here, check the CFPB’s Style Guide.
CFPB Supervision Style Guide (May 2014) 1

I. Preferred Usage of Common Words and
Phrases (A-Z)
A
a, an (when Use a before a consonant sound; use an before a vowel sound.
preceding A simple test is to choose a or an according to the way the letter or numeral is
abbreviations) pronounced.
an FBI agent (an “f”)
an LMI area (an “l”)
a CD (a “c”)
a POS terminal (a “p”)
a $5.00 bill (a “five")
abbreviations Spell out full name with the abbreviation in parentheses; do not use quotes
around the abbreviation in parentheses. May use the abbreviation in
subsequent references.
Use abbreviations for proper names only if the reference is clear. In addition,
consider using abbreviations instead of acronyms in documents referencing
entities with similar names. Compare the acronyms and abbreviations for
American Express Bank, FSB and American Express Centurion Bank in the
following:
The CFPB coordinated supervisory reviews of AEFSB and AECB with
prudential regulators.
to the preferred
The CFPB coordinated supervisory reviews of AMEX FSB and AMEX

Centurion with prudential regulators.
acronyms Spell out full name with the acronym in parentheses; do not use quotes around
the acronym in parentheses. May use the acronym in subsequent references in
upper-case with no periods.
Today the Consumer Financial Protection Bureau (CFPB) announced that
it is proposing to amend Regulation X, which implements the Real Estate
Settlement Procedures Act (RESPA).
To make an abbreviation plural, add a lowercase “s”:

The EICs from the CFPB and the FDIC met with Bank management to
discuss the findings at the joint consumer compliance examination.
If the acronym is being used as a noun, precede the acronym with the.

However, when the acronym is for a statute, do not precede the acronym with
the.
The examiner discovered incorrect disclosures at the ATM.
The Bank was previously examined by the OCC.
We found no violations of HMDA and ECOA.
Avoid using acronyms that are not in common usage. Compare:

The Bank does not offer DAPs.
to the preferred
The Bank does not offer deposit-advance products.
addendum Plural is addenda.
ad hoc In general, italicize anything in a foreign language, including Latin.
adjustable-rate, Use hyphen when used as a compound adjective.

adjustable rate Many borrowers are not aware if their adjustable-rate mortgage is tied to
the LIBOR index.
Use two words and no hyphen when rate is used as a noun.

Mortgages are offered in adjustable rates that are tied to such indices as
the LIBOR, Cost of Funds Index, and U.S. Treasury rates.
administration Lowercase.
Carter administration
African Preferred to Black when referring to a racial characteristic protected against

American discrimination by the Equal Credit Opportunity Act.
When used as a noun, do not hyphenate.

The statistical analysis indicated that African Americans were treated
less favorably than non-Hispanic Whites.
When used as an adjective, hyphenate African-American.

The statistical analysis indicated that African-American borrowers were
treated less favorably than non-Hispanic White borrowers.
agree to, Agree to means to give assent.

agree with The board agreed to the penalty the CFPB imposed on the Bank.

Agree with means to concur.
The West Bank’s Compliance Officer agreed with the examiner’s findings.
a.m., Use lowercase and periods.

p.m.
appendix(ces) Capitalize when referring to a specific appendix.

The Appendix to the privacy rule contains model language (Sample
Clauses) that institutions may use in privacy notices to satisfy the
privacy rule.
Plural is appendices.
affect, Affect, usually used as a verb, means to influence or change.

effect The violation affected the way management handled the situation.
Affect can also mean to act in a way you do not feel.

He affected an air of superiority.
Effect, usually used as a noun, means a result.

A supervised entity’s filing an appeal will not have a negative effect on its
supervisory relationship with the CFPB.
assure, Assure means to give confidence to.

ensure The Bank assured the examiner that all documents were provided.
Ensure means to make certain. It is normally followed by that.

The compliance manager ensured that the report was complete.
automatic teller May use acronym initially without the full term because of the acronym’s
machine (ATM) common usage.
attorney(s) Use lowercase when referring generically to state attorneys general. Capitalize
general when referring to a specific state attorney general.
North Carolina Attorney General Roy Cooper made a statement.
Add “s” to attorney when talking about more than one attorney general.
The attorneys general of Maryland and Virginia filed suit against the Bank.
B
bank, May use the term banks informally when referring to all depository
banks institutions, credit unions, and their affiliates.

When referring to a specific bank, after the first usage of the entity’s proper
name, put Bank in parentheses. Then, in subsequent references, use Bank.
Use uppercase when referring to a specific Bank throughout a document.
The Bank of the Atlantic Ocean (Bank) began operations in 2001. The
Bank has a strong compliance management program.
NOTE: The examples in the Supervision Style Guide capitalize Bank

when the examples are written as if referencing a specific bank.
Use it when referring to a singular bank. Do not use they.

The Bank’s operations staff consulted its chief compliance officer when
reviewing its Home Mortgage Loan Application Register data.
When referring to multiple banks, use they.

Only a few banks are located in that city; they constitute a small segment
of the market.
billion Use the dollar sign, a number, and the word billion. Use no more than one
digit after the decimal point.
The Bank had $20.3 billion in assets as of December 31, 2011.
bill pay, Use hyphen when used as a compound adjective.

bill-pay The Bank discontinued its bill-pay program.
Use two words and no hyphen when used as a noun.

The financial institution advertises its automated bill pay as a tool for
college students to avoid damaging their credit score.
board of Use lowercase. Capitalize when used as a proper noun (i.e., preceded by
directors proper name).
(board) The board of directors acknowledged the examination rating.
Bank of America’s Board of Directors responded to the CFPB

Examination Report on July 1, 2013.
C
canceled, Use one “l.”
canceling
cash flow Two words.

CEO May use acronym, without defining it first, in lieu of chief executive officer
because of the acronym’s common usage. Spelling out chief executive officer
initially is not necessary.
chief compliance Capitalize only when used as a formal title or when prefaced with a proper
officer name.
Chief Compliance Officer John Smith met with examiners to discuss the
entity’s policies and procedures.
West Bank’s Chief Compliance Officer ensures that all staff have training
in the Federal consumer financial laws pertinent to their jobs.
Use lowercase in all other uses.

The chief compliance officer updated the Bank’s policies and procedures
to reflect new regulatory changes.
civil money Spell out full term with acronym in parentheses; may use acronym in
penalties (CMPs) subsequent references. Do not use periods with acronym.
compliance audit When describing one of the components of a compliance management

system, use the term compliance audit.
Examiners’ review of West Bank’s compliance management system
found that the Bank does not conduct compliance audits.
Avoid using internal audit or quality control when discussing a

compliance audit in general. These terms typically encompass
compliance as well as safety and soundness reviews, the latter of which
is not part of a compliance audit.
However, when discussing a specific program of an entity, use the term

that the entity uses and then clarify whether the term encompasses
compliance.
Examiners review of West Bank’s internal audit program found
that the Bank’s program does not cover compliance with Federal
consumer financial laws.
compliance Use lower case except for the acronym and a proper name. Spell out
management full term with acronym in parentheses; may use acronym in subsequent
system (CMS) references.
Examiners reviewed the compliance management system (CMS) at
the entity during the last examination. They found the CMS
adequate for the entity’s operations.
West Bank’s Office of Compliance Management System is new.

congressional Use lowercase.
Consumer Spell out full name of agency with acronym in parentheses; may use acronym
Financial in subsequent references. Do not use Bureau.
Protection
Bureau (CFPB) When used as a noun, precede CFPB with the word the.
The CFPB issued its first enforcement action against the Bank.
consumer Do not use this term when referring to laws under the CFPB’s jurisdiction.
financial Instead, use Federal consumer financial laws. See Federal consumer financial
protection laws laws.
consumer Do not use acronym CRA to refer to consumer reporting agency. Always use
reporting agency the full term consumer reporting agency. The acronym CRA commonly refers
to the Community Reinvestment Act.
The three large consumer reporting agencies that most consumers are
familiar with are: Experian, Equifax, and TransUnion.
corporation Capitalize corporation when part of a proper name. May abbreviate and use
Corp. when the term comes at the end of a proper noun. Always spell out
corporation when it occurs elsewhere in the name.
Dell USA Corp.
Corporation for Public Broadcasting
cost-effective Use hyphen.
credit card bill, May use either credit card statement or credit card bill. Whichever term is
credit card used, use it consistently within a document.
statement
D
data Data is a plural noun; always use a plural verb.
Personal financial data are treated confidentially by the human
resources department.
data-driven Use hyphen.
decision-making Hyphenate when used as a compound modifier, as in decision-making

process. Avoid as a noun or verb; use decision or decide instead.
Dodd-Frank Wall In formal documents, spell the full name of the statute with acronym in
Street Reform parentheses; may use the acronym in subsequent references.

and Consumer
Protection Act of In informal documents, may use only the Dodd-Frank Act.
2010
(Dodd-Frank
Act)
denial Use denial when referring to loan applications that are denied by an entity.
Do not use declination.
For home improvement applications received in 2012, the entity’s
denial rate was 32 percent for African Americans and 10 percent for
Asians.
depository Use depository institution when referring to banks, savings associations,

institution credit unions, and their affiliates.
Use it when referring to a singular depository institution. Do not use they.
When referring to multiple depository institutions, use they.
different from, Use different from when followed by a noun and describing items that are
different than, unlike.
differ with The CFPB’s focus on practices that pose risks to consumers is different
from prudential regulators’ focus on practices that pose risks to a
bank.
If a clause, having a subject and verb, follows different, then use than.
The CFPB way is different than I expected.
Differ with means to disagree.

The Bank’s management differed with examiners on the examination
findings.
downpayment One word.
due diligence Two words.
E
e-banking Use lowercase and hyphen.
e.g., Abbreviation for the Latin words for for example. Always use with periods
and followed by a comma. Do not italicize. Do not confuse with i.e. which
is the Latin abbreviation for that is; also means in other words. Compare:

I like root vegetables, e.g., potatoes.
to
I like root vegetables; i.e., the ones that grow underground.
HINT: Both e.g. and example begin with the letter e.
elderly When discussing age discrimination under the Equal Credit Opportunity Act,
use elderly to refer to consumers who are age 62 or older.
email Use lowercase and no hyphen.
etc. Always use as an abbreviation; do not use etcetera. Do not italicize.
If phrase or list starts with for example or including, do not use etc. at end of
it.
examination Use examination when referring to a point-in-time examination where

examiners assess an entity’s compliance management program and evaluate
compliance with one or more institution product lines. As a result of an
examination, the CFPB issues an examination report to a supervised entity;
the report includes a consumer compliance rating.
Do not use exam.
Examination When referencing a specific examination report, spell out Examination

Report (Report) Report on first usage with Report in parentheses; may use Report in
subsequent references. Capitalize Examination Report or Report when
referencing a specific examination report.
examiner Lowercase.
examiner-in- Use hyphens with the full term. Spell out full term with acronym in
charge (EIC) parentheses; may use acronym in subsequent references. Do not use periods
with acronym.
F
Fair Housing Act Use FHAct for the acronym. Do not use acronym FHA for the Fair Housing
Act because the acronym FHA more commonly refers to the Federal Housing
Administration.

federal Use lowercase except as part of a proper noun, when citing a specific statute,
or when discussing consumer financial laws collectively
Federal Bureau of Investigation
Federal Deposit Insurance Act
Federal consumer financial laws
federal banking Use this term when collectively referring to the FDIC, the Federal Reserve,
agencies and the OCC.
Federal Use this term when referring to specific laws enumerated in Section
consumer 1002(12) of the Dodd-Frank Act. These are the laws the CFPB has authority
financial laws to enforce. Before using the term, confirm that the statutory definition covers
the context in which the term is being used.
Do not add and regulations after the term since regulations are included in
the Dodd-Frank definition of Federal consumer financial laws.
Federal should always be capitalized in this instance.
Do not capitalize law. You may pluralize law.
federal financial Use this term when referencing other (i.e., non-CFPB agencies) supervisory
institution agencies collectively. However, do not use it when referring collectively to
regulatory agencies when also including the CFPB. See Federal financial supervisory
agencies agencies.
federal financial Use when referring collectively to:

supervisory • Board of Governors of the Federal Reserve System,
agencies • Federal Deposit Insurance Corporation,
• National Credit Union Administration,
• Office of the Comptroller of the Currency, and
• if referring to post-July 20, 2011, Consumer Financial Protection Bureau,
or
• if referring to pre-July 21, 2011 date, Office of Thrift Supervision.
federal Use lowercase for federal government. Use capital letters and periods for
government, U.S. government.
U.S. government
Federal Register Use italics for Federal Register. Use Fed. Reg. for abbreviation.
(Fed. Reg.)
fewer, Use fewer for things that are countable; use less for things that are not
less countable. HINT: If the noun can be preceded by a number (one branch, 19
violations), modify the noun with fewer, as shown by the following examples.

The Bank originated fewer loans in 2012 in Virginia than it did in 2011.
The violations found at the current examination were less serious and did
not require the attention of the board of directors.
However, less than is used in front of a plural noun that denotes a measure of
distance, time, or amount.
The branch is located less than 2 miles from the MSA.

The onsite portion of the examination will end in less than 4 weeks.
Less than 5 inches of snow fell on the nation’s capital in January.
financial Use financial institution when referring to either a depository or a non-

institution depository entity.
Use it when referring to a singular financial institution. Do not use they.
When referring to multiple financial institutions, use they.
fiscal year(s) When referring to a specific fiscal year, use FY immediately before the year,
without a space. Use all four digits of the year. The fiscal year is designated
by the year in which the fiscal year ends; for example, fiscal year 2013
begins on October 1, 2012 and ends on September 30, 2013.
The CFPB planned a target examination at Bank of the Pacific in
FY2012.
NOTE: The CFPB operates on a fiscal year, October 1st to September

30th.
fixed rate, Use two words and no hyphen when used as a noun.
fixed-rate The homeowner mistakenly thought his mortgage had a fixed rate.
Use hyphen when used as a compound adjective.

The examiners found only 10 percent of the sampled minority
homeowners received a fixed-rate mortgage.
follow up, Use two words and no hyphen when used as a verb.
follow-up The examiner will follow up on the corrective actions taken at the next
examination.

The Bank submitted a follow-up report to examiners prior to the on-site
portion of the examination.
full-scope Use lowercase and hyphen.

G
Good Faith Spell out full term with acronym in parentheses; may use the acronym in
Estimate (GFE) subsequent references.
government Spell out full term with acronym in parentheses; may use the acronym in
sponsored subsequent references.
enterprise (GSE)
H
Headquarters Capitalize when designating the CFPB’s head office in Washington, D.C.
Hispanic When discussing national origin discrimination under the Equal Credit
Opportunity Act, use either Hispanic or Latino.
Use upper case for Hispanic. Also, for non-Hispanic White, use upper
case for Hispanic and White but lower case for (and a hyphen after) non.
homeowner One word.
home ownership Two words.
I
i.e., Abbreviation for the Latin words for that is. Also means in other words.
Always use with periods and followed by a comma. Do not italicize. Do
not confuse with e.g., which is the Latin abbreviation for for example.
Compare:
I like root vegetables; i.e., the ones that grow underground.
to
I like root vegetables, e.g., potatoes.
Internet Use uppercase.
its, Its is possessive; do not use an apostrophe. It’s means it is. In formal
it’s documents, use it is; do not use the contraction it’s.

The Bank provided its responses to the CFPB’s information request on
January 1st.
It is unlikely that the Bank will agree to the formal enforcement action
currently being proposed by its supervisor.
K
L
Latino When discussing national origin discrimination under the Equal Credit
Opportunity Act, use either Hispanic or Latino.
Use upper case.
less, Use fewer for things that are countable; use less for things that are not
fewer countable. HINT: If the noun can be preceded by a number (one branch,
19 violations), modify the noun with fewer.
The Bank originated fewer loans in 2012 in the state than it did in
2011.
The violations found at the current examination were less serious

and did not require the attention of the board of directors.
However, less than is used in front of a plural noun that denotes a

measure of distance, time, or amount.
The branch is located less than 2 miles from the MSA.
The onsite portion of the examination will end in less than 4 weeks.
Less than 5 inches of snow fell on the nation’s capital in January.
loan, Use loan as a noun and lend as a verb.

lend The Bank does not offer that type of loan.
The Bank lends a wide variety of mortgage products to consumers in

that market.
logos for credit card When referring to the logo on a credit card (i.e., Visa, MasterCard,
brand networks Discover, or American Express), call it a network-branded card. Use
the full term throughout for clarity.
While private label gift cards are accepted by only a few merchants,

network-branded cards (e.g., VISA and MasterCard) can be used
wherever such network-branded cards are accepted.
long term, Use two words and no hyphen when used as a noun.
long-term We will win in the long term.

A team of Northeast examiners were placed on a long-term
assignment in Providence, RI.
low- and moderate- Use hyphen after both low and moderate, with a space after low-.
income housing
M
majority Use when meaning more than half the amount.
The majority of state governors (i.e., 26 of the 50 governors)
attended the national meeting.
Matter Requiring Capitalize and spell out full term with acronym in parentheses on first
Attention (MRA) reference; may use acronym in subsequent references. Always
capitalize the acronym. Plural is Matters Requiring Attention or MRAs.
Memorandum of Spell out full term with acronym in parentheses; may use acronym in
Understanding subsequent references. Plural is memoranda of understanding or
(MOU) MOUs. Always capitalize the acronym.
metropolitan Spell out full term with acronym in parentheses; may use acronym in
statistical area subsequent references.
(MSA)
millions Use the dollar sign, a number, and the word million. Use no more than
one digit after the decimal point. Do not use the Roman number MM to
denote one million.
The company had a loss of $10.2 million in net income last year.
multifamily No hyphen.
N
nationwide One word.

nonbank entity Use when referring to companies that provide consumer financial
products and services, but are not banks, savings associations, credit
unions, or their affiliates.
One word.
Do not use only nonbank. Always use the term nonbank entity or, after
the first usage of nonbank entity, may simply use entity. Synonymous
with nondepository institution.
non-compliance Use hyphen.
O
off-site Use hyphen.
online One word.
on-site Use hyphen.
open-end Use hyphen.
open- and closed-end Use hyphen after both open and closed, with a space after open-.
opt out, Use opt out (written without a dash) as a verb. Use opt-out is an
opt-out adjective. Use opt in and opt-in similarly.
The consumer opted out of the Bank’s overdraft protection
opt in, program.
opt-in
The Bank failed to provide opt-out notices to consumers.
overlimit fee One word. Do not use over limit fee.
P
part Capitalize when referring to a regulation.
The CFPB regulations can be found in Title 12 CFR Parts 1000-
1099.
payday One word.
percent One word. Do not use “%” in narratives. Use numbers in advance of

percent, including numbers less than 10 unless the number is zero in
which case spell out zero.
5 percent
zero percent, but not 0 percent.
Use one digit after the decimal point.

23.4 percent
point-in-time Use hyphens.
point-of-sale (POS) Spell out full term with acronym in parentheses; may use acronym in
subsequent references.
policymaking, One word.

policymaker
preapproved One word.
precommission One word.
prepaid One word.
prequalified One word.
prepayment One word
prescreened One word.
president Capitalize only when used as a formal title.

President Obama was elected for a second term.
Use lowercase in all other uses.

The president of the Bank did not attend the meeting with
examiners.
principal, The noun principal means head or chief.

principle George Jones is the principal of the school.
The examiners met with the principals of the nonbank entity to
discuss the examination findings.
The adjective principal means leading.

John Smith is the principal investigator of the case.
The principal of a loan means the amount borrowed.

They plan to pay off the principal of their mortgage in 15 years.

The noun principle means truth, belief, policy, conviction, or general
theory.
The CFPB’s principles include ensuring that all consumers have
access to markets for consumer financial products and services and
that markets for consumer financial products and services are fair,
transparent, and competitive.

R
race For information monitoring purposes, Appendix A to Regulation C
(Home Mortgage Disclosure Act) lists reporting codes for the following
races.
• American Indian or Alaska Native,
• Asian,
• Black or African American
(NOTE: African American is the preferred term when writing
supervision documents.)
• Native Hawaiian or Other Pacific Islander, and
• White
NOTE: Hispanic or Latino refers to ethnic categories, not to race.
See African American for the preferred style when using the term as a
noun or adjective.
record keeping Two words.
rulemaking, One word.

rulewriting
S
Section Capitalize when referring to a specific section of the Dodd-Frank Act or
other laws.
The CFPB’s authority for prohibiting unfair, deceptive, or abusive
acts or practices can be found under Section 1031 and Section 1036
of the Dodd-Frank Act.
self-evaluation, Used self-test when describing a program, practice, or study that is

self-test designed and specifically used to assess the institution’s compliance with
fair lending laws that creates data not available or derived from loan,
application, or other records related to credit transactions (12 CFR
202.15(b)(1) and 24 CFR 100.140 to 100.148)).
Use self-evaluation when describing a program, practice, or study that,

while generally having the same purpose as a self-test, does not create any
new data or factual information, but uses data readily available in loan or
application files and other records used in credit transactions and,
therefore, does not meet the self-test definition.
Self-assessment usually covers both self-tests and self-evaluations.

Be specific in using these terms.
service provider Two words. Do not use vendor.
Service provider is defined generally in section 1002(26) of the Dodd-

Frank Act as:
…any person that provides a material service to a covered person in
connection with the offering or provision by such covered person of
a consumer financial product or service ….
Refers to a provider that may or may not be affiliated with the person to
which it provides services.
servicemember One word.
skill set Two words.
single-family Use hyphen.
state Use lowercase.

The CFPB is preparing to sign a Memorandum of Understanding
with the state of California.
supervised entity(ies) Use supervised entity when referring to either a depository or

nondepository entity.
Supervisory Letter When referencing a specific supervisory letter, spell out Supervisory
(Letter) Letter on first usage with Letter in parentheses; may use Letter in
subsequent references. Capitalize Supervisory Letter or Letter when
referencing a specific supervisory letter.

T
that, which Use that in a restrictive clause, which is essential to the meaning of the
sentence. Do not use commas to set off the clause.
The Bank’s policy that loan application records be retained for 24
months did not comply with Regulation B’s record retention
requirement of 25 months (12 CFR 1002.12(b)(3)).
Use which in a nonrestrictive clause, which is not essential to the

meaning of the sentence (it merely adds further information). If
removed, it does not change the meaning of the sentence. Use commas
to set off the clause.
The Bank, which offers only 30-year mortgages, does not sell its
mortgage loans to the secondary market, keeping them instead in its
own portfolio.
third party, Use two words and no hyphen when used as a noun.
third-party The Bank services its loans through a third party.

The Bank uses a third-party service provider to collect past due
debts.
time frame Two words.
thousands For dollar values in the thousands, use numbers. Do not use the Roman
number M to denote one thousand.
$200,000
U
underrepresented One word.
unfair or deceptive Use when referencing Section 5 of the Federal Trade Commission Act.
acts or practices Spell out full term with acronym in parentheses; may use acronym in
(UDAPs) subsequent references.
Section 5 of the Federal Trade Commission Act prohibits unfair or
deceptive acts or practices (UDAPs).
NOTE: The CFPB does not enforce Section 5 of the FTC Act; the
prudential regulators do.
unfair, deceptive, or Use when referring to the CFPB’s rulemaking, supervision, and
abusive acts or enforcement authority under Sections 1031 and 1036 of the Dodd-Frank

practices (UDAAPs) Act. Spell out full term with acronym in parentheses; may use acronym
in subsequent references.
The CFPB examiners reviewed the Bank’s credit card notices for
potential unfair, deceptive, or abusive acts or practices (UDAAPs).
V
variable rate, Use two words and no hyphen when used as a noun.
variable-rate The homeowner mistakenly thought his mortgage had a variable rate.

The examiners found only 10 percent of the sampled homeowners
received a variable-rate mortgage.
W
web Use lower case for the following:
web, web page, website, webcam, webcast, and webmaster.
Do not include www. in front of the domain name. All websites should
be hyperlinked, if possible.
which, that Use that in a restrictive clause, which is essential to the meaning of the
sentence. Do not use commas to set off the clause.
The Bank’s policy that loan application records be retained for 24
months did not comply with Regulation B’s record retention
requirement of 25 months (12 CFR 1002.12(b)(3)).
Use which in a nonrestrictive clause, which is not essential to the

meaning of the sentence (it merely adds further information). If
removed, it does not change the meaning of the sentence. Use commas
to set off the clause.
The Bank, which offers only 30-year mortgages, does not sell its
mortgage loans to the secondary market, keeping them instead in its
own portfolio.
workpapers One word.

Y
year-end Use hyphen when year-end is used as a noun or an adjective.
year-to-date Use hyphens.

II. Preferred Punctuation and Formatting
(A-Z)
apostrophes To indicate possession, add only an apostrophe to a noun ending in s or an s
sound:
Harris’ statement
Lopez’ account
Because joint possessors are considered a unit, use only one apostrophe and s
after the second possessor:
A father and son’s account
For separate or alternative possessors, use an apostrophe and an s after each

possessor:
Neither the examiner's nor the external auditor’s recommendations were
acted upon by the Bank.
Use apostrophes to resolve any ambiguities related to possession. Compare:

The dislike of bankers for the new law was widely known.
to the preferred
Bankers’ dislike of the new law was widely known.
Note that the dislike of bankers can momentarily be construed as an

aversion to bankers.
Use apostrophes to make writing more concise:

Determine whether the definition of default used by the model is
acceptable.
to the preferred
Determine whether the model’s definition of default is acceptable.

bulleted lists Limit bulleted lists to single phrases whenever possible.
For lists that do not comprise complete thoughts or sentences, capitalize the
first letter in the line item and do not put periods at the end.
In order to protect consumers, the CFPB’s actions include:
• Conducting rule-making, supervision, and enforcement for Federal
consumer financial laws;
• Restricting unfair, deceptive, or abusive acts or practices;
• Taking consumer complaints; and
• Promoting financial education.
For lists that do consist of complete thoughts or sentences, capitalize the first
letter in the line item and end the line item with a period.
Consumers should always remember to:
• Read their statements every month.
• Check their balances before making ATM withdrawals.
• Look for ATMs within their bank’s network to avoid surcharges.
Use parallel structure in all lists. Compare:

Incorrect list that is not in parallel structure:
The Bank was required to:
• Correct the errors on its HMDA LAR
• Its HMDA LAR must be resubmitted.
• Training its employees on HMDA compliance.
Correct list that is in parallel structure:

The Bank was required to:
• Correct the errors on its HMDA LAR.
• Resubmit the HMDA LAR.
• Train its employees on HMDA compliance.
When a document makes reference to an item in a list, use numbered lists

instead of bulleted lists to facilitate reference to items in a list.
In Jefferson County, the Bank does not offer the loan types listed in items d
through h on page 12 of its loan policy.
capitalization Capitalize the names of government agencies, agency departments, agency

(names of divisions, acts, committees, plans, programs, and reports whenever the names
entities) appear in their entirety. In addition, capitalize one-word generic terms
referring to these entities.
the Community Reinvestment Act, the Act
the Department of State, the Department
the Federal Deposit Insurance Corporation, the Agency
commas In a list of three or more items, use a serial comma immediately before a

conjunction preceding the final item.
Good Faith Estimate, Uniform Settlement Statement, and Notice to
Borrower of Transfer of Mortgage Servicing
West Region, Midwest Region, Southeast Region, and Northeast Region
Do not use a comma between month and year.

June 2012
Use a comma before and after the year when the month and day precede the
year.
The examiners completed the May 31, 2010, supervisory letter that
concluded the Bank’s compliance management system needed to be
strengthened.
commas v. Follow these general rules for commas v. semicolon v. period separation.
semicolon v.
period Use commas to separate bullet points when there is an introductory statement
separation but no internal punctuation within each item listed. For example:
While on an examination, we are careful to check for the following issues:
• Miscalculated APRs,
• Misstated introductory rates, and
• Hidden fees that were not disclosed to the borrower.
Use semicolons to separate bullet points when the items listed contain internal
punctuation. For example:
The Bank had operations in the following U.S. cities and foreign countries:
• New York City, San Francisco, and Chicago; and
• Mexico, Canada, and United Kingdom.
Use a period after each bullet point when items listed are sentences.
Below is a list of recommended ways to improve your grade.
• Study at least 3 hours per day.
• Reach out to teachers when you do not understand a lesson.
• Do not stay out late the night before exams.
contractions Do not use contractions. Compare:

The Bank’s president didn’t attend the final meeting with examiners.
to the preferred:
The Bank’s president did not attend the final meeting with examiners.
dash Use dash from keyboard, with a space before and after the dash ( - ).
2010 - 2012; Pages 1003 - 1033; June - December

dates In formal documents, including in CFPB examination reports and supervisory
letters, spell out the name of the month, followed by the date and year.
The examination commenced on January 2, 2013.
In informal documents, may use the full numerical format with four digits for
the year.
Please forward comments on the draft Examination Report by 3/17/2013.
When a full date (month, day, and year) appears before the end of a sentence,
include a comma after the year, as shown below (i.e., the comma after
November 24, 2011 and after July 4, 2014).
The on-site examination began November 24, 2011, and ended January 13,
2012.
The review period was from July 4, 2014, to August 20, 2014.
If referring to a time, date, and place in one sentence, order as follows:

• time first, then date, then place.
The close-out meeting with the board of directors will be held at 10:00
a.m. on June 25, 2012, in Washington, D.C.
dollars Use lowercase.
Use $ sign and figures in all except casual references or amounts without a
figure.
The book cost $4.
Please give me a dollar.
Dollars are flowing overseas.
For specific amounts, use a singular verb.

He said $500,000 is what they want.
For amounts of more than $1 million, use one digit after the decimal place. Do
not link the numerals and the word by hyphen.
He is worth $4.3 million.
He is worth exactly $4,351,242.
He proposed a $300 billion budget.
Use the following form for amounts less than $1 million.

$4; $25; $500; $1,000; $650,000.
For additional guidance, refer to thousand, million, and billion in Preferred

Usage of Common Words and Phrases (A – Z).

fonts Use the following font styles in CFPB supervisory letters and examination
reports:
• Heading type font: Verdana
• Heading font size: varies
(See templates for examination reports and supervisory letters found in
SES under “Examination Documents/Shell Documents.”)
• Body text type font: Times New Roman

• Font size: 12
hyphen A hyphen clarifies the relationship between words that are combined to modify
a noun. The hyphen shows that the words do not modify the noun separately.
Compare:
Old-furniture salesman refers a salesman of old furniture.
to
An old furniture salesman refers an old salesman who sells furniture.
Typically, hyphenate compound modifiers when they come before a noun and
do not hyphenate them when they come after a noun.
The second-rate opera company gave a performance that was first rate.
Compare:
fifty-yard-wide field
fire-resistant curtains
to
a field fifty yards wide

curtains that are fire resistant
italics Use italics to highlight the names of books, newspapers, journals and
pamphlets. Place in quotation marks the titles of booklets, articles, and other
publications that are part of an italicized work.
Use italics to emphasize words or phrases. In most texts, bold is too much
emphasis.
Italicize words or phrases when discussing what they mean or how they
function.
In general, italicize anything in a foreign language, including Latin.

Ad hoc
Et seq.

legal citations See section on Frequently Referenced Statutes and Regulations.
numerals Use numerical digits for 10 and above and spell out whole numbers below 10.
However, when a number less than 10 appears before percent, use the
numerical digit except for zero percent.
The Bank has five branches (17 percent of total branches) in low- to
moderate-income areas, 25 (83 percent) in middle-income areas, and none
(zero percent) in upper-income areas.
Of all loans, 35 percent were commercial loans and 55 percent were

consumer loans. Only 5 percent were construction loans and 0.9 percent
agricultural loans.
Spell out a numeral at the beginning of a sentence.

Twenty-five percent of the Bank’s loans were commercial loans.
For ordinal numbers, spell out first through ninth and use figures for 10th and
above.
The examination was the first one conducted by the CFPB.
The Bank is the 12th largest in the United States based on asset size.
Spell out the fractions less than one, using a hyphen between the words (e.g.,
two-thirds, four-fifths, one-half). When using decimals for amounts less than
one, use the numeral zero before the decimal point (e.g., 0.03).
Use figures for precise amounts larger than one, converting fractions to
decimals whenever practical (e.g., use 1.5 instead of 1½ or 2.75 instead of
2¾).
page numbers Paginate all documents. Use the pagination embedded in SES templates. For
other documents, center the number at the bottom of the page, in the same font
as the rest of the document. Generally begin pagination on page 2 of a
document.
periods May use either one space or two spaces after a period or any other punctuation
that concludes a sentence. Whichever is used, use it consistently within a
document.
quotation Place end quotation marks outside of commas and periods, and inside
marks semicolons, exclamation marks, and question marks (except when exclamation
marks or questions marks are part of the quotation).
The Bank asked the committee to act “with discretion”; the Bank agreed
not to act until an updated contract was signed.
In recordings of consumer service representatives, examiners heard

customers ask the representatives, “Has the Bank made a final decision on

my refinancing loan yet?”
spacing May use single or double spacing after a period. Whichever is used, use it
consistently within a document.
telephone Use the following format in documents:

numbers 202-555-5555.
time Generally, use figures to denote time as follows:

10:00 p.m.
12:15 a.m.

voice Use the active voice where the subject of the sentence performs the action.
The active voice is more direct and forceful than the passive voice. It tells the
reader who is doing what. Do not overuse the passive voice. Compare:
All proposals are reviewed monthly by the committee. (passive)
to the preferred
The committee reviews all proposals. (active)
HINT #1: If you are unclear whether a sentence is in the passive voice, a
general rule of thumb is to add by John Smith right after the verb. If the
sentence makes sense with by John Smith added, then the sentence is in the
passive voice. For example, if the sentence above only said All sentences
are reviewed monthly, you could add by John Smith, and the sentence
would make sense; thus it is in the passive voice:
The policy was drafted in July 2011 [by John Smith].
Compare the above sentence in the passive voice to the following sentence
in the preferred active voice:
John Smith drafted the policy in July 2011.
HINT #2: In Word, turn on the proofing option to check for Grammar and
Style.

III.Preferred Terminology in CFPB
Supervision Documents (A-Z)
concurrent examination Use when referring to an examination conducted at the same time by
the CFPB, prudential regulators and/or state regulatory authorities,
where each supervisor issues its own examination report. In contrast,
see coordinated examination, joint examination, and simultaneous
examination.
comparative file review Use the term comparative file review when referencing an
analysis as described in the Interagency Fair Lending
Examination Procedures.
Do not use the term matched file review or matched pair

review.
coordinated Use when referring to general supervision activities, such as scheduling

examination examinations, undertaken by the CFPB, prudential regulators and state
regulatory authorities in an effort to reduce regulatory burden on
supervised entities. In contrast, see concurrent examination, joint
examination, and simultaneous examination which involve reviews of
specific entities and result in examination reports issued individually or
jointly by the agencies.
in compliance Do not state that an entity is in compliance with Federal consumer

financial laws since this implies that examiners conducted a
comprehensive review of all legal requirements. Instead, in a risk
focused examination, after summarizing the scope of a review, state
the results of the review. For example:
We sampled notices of action taken that were sent to loan
applicants during the last quarter of 2012. We found no
violations of Regulation B’s notice requirements (12 CFR
1002.9)
joint examination Use when referring to an examination conducted by CFPB,

prudential regulators, and/or state regulatory agency, where the
agencies conduct examination activities together and issue one
examination report. In contrast, see concurrent examination.
coordinated examination, and simultaneous examination.
matched pair Do not use this term when referencing an analysis as described in the
Interagency Fair Lending Examination Procedures. Use
comparative file review. See entry for comparative file review.

personally identifiable Do not use personally identifiable information when, for example,
information describing transactions containing violations of Federal consumer
financial laws (provide such detail directly to management of the
supervised entity). Instead, describe the transactions in general
terms. Compare:
Examiners identified violations of Regulation B’s adverse action
requirements in the following mortgage loans:
• Smith (#1123434) - incorrect reason for denial;
• Jones (#6843513) - incorrect reason for denial; and
• Garcia (#468467) - no adverse action notice provided to
consumer
to the preferred:
Examiners reviewed 25 mortgage loan files and identified

violations of Regulation B’s adverse action requirements:
• Two loans - incorrect reason for denial; and
• One loan - no adverse action notice provided to consumer.
resubmit Use these terms when discussing a supervised entity’s need to resubmit
resubmission its HMDA LAR data. Do not use refile.
simultaneous Use simultaneous when describing examinations conducted with a

examination prudential regulator, as required by Section 1025(e) of the Dodd-Frank
Act. According to the May 16, 2012, Interagency Memorandum of
Understanding on Supervisory Coordination:
… examinations are “simultaneous” if material portions of Covered

Examinations by the Prudential Regulator and the CFPB are
conducted during a concurrent time period pursuant to each
Agency’s procedures in order to further the objectives of this MOU,
although more overlap may occur on a voluntary basis.
For further information, refer to the Memorandum

(http://files.consumerfinance.gov/f/201206_CFPB_MOU_Supervisory_Coordination.pdf).

technical violation, Avoid using technical violation and technical requirements. Instead,
technical requirements be more specific and explain the violation or requirements.
Examiners found violations of Regulation Z’s disclosure
requirements for closed-end credit.
Examiners reviewed compliance with Regulation B’s adverse

action notice and record retention requirements.
unfair, deceptive, or When writing an examination report or supervisory letter, do not say
abusive acts or practices that the entity is “in compliance with UDAAPs.” Instead write that,
(UDAAPs) “As a result of their review, the examiners did not identify any
UDAAPs” or the entity “avoided UDAAPs.” For example:
After a thorough review, examiners did not identify any unfair,
deceptive, or abusive acts or practices.
Examiners reviewed the Bank’s operations to determine whether

it engaged in unfair, deceptive, or abusive acts or practices
(UDAAPs) and whether it had policies and procedures to avoid
UDAAPs.

IV. Referencing Statutes and Regulations
The CFPB examines supervised entities under its jurisdiction for compliance with the Federal
consumer financial laws enumerated in the Dodd-Frank Act (see Federal consumer financial law
under Section 1002 of the Dodd-Frank Act. In addition, see Identification of Enforceable Rules
and Orders at 76 Federal Register 43569 (July 21, 2011)). When discussing one of these laws,
examiners should reference the actual statute or regulation (see the list in this chapter for
commonly referenced laws). In addition, to assist examiners when citing violations of such laws,
a working list of statutory and regulatory citations can be found in SES in two locations: first,
under Help, and second, within an actual examination record (view/update exam data).
Guidance of other agencies. The CFPB generally does not consider guidance or similar
documents issued by other agencies in connection with laws that transferred to the CFPB to be
within its enforcement authority. However, for laws for which rulemaking authority transferred
to the CFPB, the CFPB will apply any official commentary, guidance, or policy statements that
were issued prior to July 21, 2011 by a transferor agency that had exclusive rulemaking authority
for the law in question, pending any future CFPB action. This would also apply to similar
documents that were jointly agreed to by all relevant agencies in the case of shared rulemaking
authority. (See 76 Federal Register 43569). For example, the CFPB would not apply to its
supervised agencies the Interagency Guidance on Overdraft Protection Program (70 Fed. Reg.
9127; February 24, 2005) since the agencies involved did not have shared rulemaking authority
for the laws governing overdrafts. In contrast, the CFPB would apply the commentary to
Regulation DD, the implementing rule for the Truth in Savings Act (TISA); the commentary was
written by the Federal Reserve Board and the Board had exclusive TISA rulemaking authority
which transferred to the CFPB.
Proposed regulations. Examiners should only cite violations of final regulations. However,
when reviewing a compliance management system, examiners may make general references to
the importance of monitoring future rulemaking so that management is aware of rulemakings
that could affect its business practices.
Referencing statutes and regulations. When discussing regulations, the initial reference should
include the name of the statute in order to inform the reader of the regulation’s subject. The
statute only has to be referenced once when introducing the implementing regulation. Compare:
The examiners reviewed the Bank for compliance with Regulation Z (12 CFR Part 1026).
to the preferred:
The examiners reviewed the Bank’s mortgage operations for compliance with the Truth
in Lending Act (TILA) and its implementing Regulation Z (12 CFR Part 1026).
For subsequent references to sections of the regulations, use the CFR reference. Do not use the
word Section before the number unless the sentence begins with the CFR citation.
Section 1022.72 of Regulation V contains the general requirements for risk-based pricing
notices.

When referencing statutes, spell out the full name of the statute when first referenced, with the
acronym in parentheses. May use the acronym in subsequent references.
If the statutory requirements are not implemented by a regulation, cite the US Code for the
statute. Do not cite the section of the statute.
Compare:
The debt collector violated Section 807 of the Fair Debt Collection Practices Act
(FDCPA) that prohibits the use of false, deceptive, or misleading representations in
connection with the collection of any debt.
to the preferred:
The debt collector violated the provisions of the Fair Debt Collection Practices Act
(FDCPA) that prohibit the use of false, deceptive, or misleading representations in
connection with the collection of any debt (15 USC 1692e).
If the statutory requirements are implemented by a regulation, do not cite the US Code. Only
cite the regulatory requirement. Compare:
The Bank violated ECOA’s requirements for record maintenance (15 USC 1691b(h)) and
the implementing Regulation B’s record retention requirements (12 CFR 1002.12(b)).
to the preferred:
The Bank violated ECOA’s implementing Regulation B requirements for record retention
(12 CFR 1002.12(b)).
An additional example where only the regulation is cited follows.

The entity violated the Fair Credit Reporting Act’s affiliate marketing requirements, as
implemented by Regulation V, by failing to provide consumers a reasonable opportunity
to opt-out of the entity’s use of eligibility information to make solicitations for marketing
purposes to the consumer (12 CFR 1022.21(a)(ii)).
Use Part only when referring to the entire regulation. Do not use Part when referring to sections
of a regulation.
The Equal Credit Opportunity Act is implemented by the CFPB’s Regulation B (12 CFR
Part 1002).
The definition of elderly can be found in 12 CFR 1002.2(o) of Regulation B.
When discussing regulations, do not abbreviate the word regulation.
Do not use the legal symbol for section: §.

When abbreviating United States Code or the Code of Federal Regulations, do not use periods
when using the acronyms USC and CFR. May use periods when only using the acronym of the
United States (U.S. Code).
In examination reports and supervisory letters, use the name of the statute and, depending on
situation, the pertinent regulation in parentheses.
Truth in Lending Act (Regulation Z) or
Truth in Lending Act and its implementing Regulation Z
Fair Debt Collection Practices Act
Commentary. When referencing the commentary of a regulation, use the following format the
first time a specific regulation’s commentary is referenced:
12 CFR Part 1005, Supp. I, Comment 2(a)-1
After the first full reference to the regulation and commentary, for subsequent references
to different commentary of the same regulation, use only:
Comment 9(a)(5)-1.

Frequently Referenced Statutes and Regulations
Statute Implementing Regulation
gpo.gov/fdsys/browse/collectionUScode.action ecfr.gpoaccess.gov
or
law.cornell.edu/uscode/text
Alternative Mortgage Transaction Parity Act • 12 CFR Part 1004
(AMTPA) (1982)
• 12 USC 3801 et seq.
Community Reinvestment Act (CRA) (1977) Regulation BB

• 12 USC 2901 et seq. • OCC: 12 CFR Part 25
• Federal Reserve: 12 CFR Part 228
• FDIC: 12 CFR Part 345
Consumer Leasing Act (CLA) (1976) Regulation M

• 15 USC 1667 et seq. • 12 CFR Part 1013
Dodd-Frank Wall Street Reform and Consumer N/A

Protection Act (Dodd-Frank Act) (2010)
• 12 USC 5481 et seq. This USC cite refers to
Title X of the Dodd-Frank Act.
• 12 USC 5514. This USC cite refers to Defining Larger Participants Of Certain
Section 1024 (Supervision of Nondepository Consumer Financial Product And Service
Covered Persons) of the Dodd-Frank Act. Markets
• 12 CFR Part 1090
• 12 USC 5512(c)(6)(A). This USC cite Disclosure Of Records And Information

refers to Section 1022(a)(6)(A) • 12 CFR Part 1070
(Confidentiality Rules) of the Dodd-Frank
Act.
Electronic Fund Transfer Act (EFTA) (1978) Regulation E

Equal Credit Opportunity Act (ECOA) (1974) Regulation B

Fair Credit Reporting Act (FCRA) (1979) Regulation V

Fair Debt Collection Practices Act (FDCPA) N/A

(1978)
• 15 USC 1692 et seq. NOTE: Regulation F (12 CFR Part 1006)

or
covers state exemptions to FDCPA.
Federal Deposit Insurance Act (FDI Act) (1950) N/A

• 12 USC 1813 et seq.
Gramm-Leach-Bliley Act (GLBA) (1999) – Regulation P

Privacy of Consumer Financial Information • 12 CFR Part 1016
• 15 USC 6801 et seq.
NOTE: Sections 502 through 509 of the

Gramm-Leach-Bliley Act of 2009 govern the
disclosure of nonpublic personal information
(except for Section 505 as it applies to Section
501(b) which governs safeguarding customer
information).
Homeowners Protection Act (HPA) (1998) N/A

• 12 USC 4901 et seq.
Home Mortgage Disclosure Act (HMDA) Regulation C

(1975) • 12 CFR Part 1003
• 12 USC 2801 et seq.
Interstate Land Sale Full Disclosure Act (ILS) N/A

(1968)
• 15 USC 1701 et seq.
Real Estate Settlement Procedures Act (RESPA) Regulation X

(1974) • 12 CFR Part 1024
• 12 USC 2601 et seq.
Secure and Fair Enforcement for Mortgage Regulation G (Federal Registration of

Licensing Act (SAFE Act) (2008) Residential Mortgage Loan Originators)
Regulation H (State Compliance And Bureau

Registration System)
• 12 CFR Part 1008
Truth in Lending Act (TILA) (1968) Regulation Z

or
15 USC 1601 et seq. • 12 CFR Part 1026
• Credit Card Accountability Responsibility
and Disclosure Act (Card Act) (2009)
• 15 USC 1602 et seq.
• Fair Credit Billing Act (FCBA) (1975)
• 15 USC 1601 et seq.
• Home Ownership and Equity Protection Act
(HOEPA) (1994)
• 15 USC 1639 et seq.
Truth in Savings Act (TISA) (1991) Regulation DD

Unfair, Deceptive, or Abusive Acts or Practices N/A

• 12 USC 5531
• 12 USC 5536

V. Frequently Referenced CFPB Offices
Capitalize when Office is used formally, at the beginning of the office’s name, but lowercase
when used informally, after the office’s name. For example, the Office of Research should not
be referred to as the Research Office, but when using it informally it would be acceptable to refer
to the research office – for example the research office conducted a study of … Do not use
acronyms in formal documents.
• CFPB’s Ombudsman’s Office

• Division of Consumer Education and Engagement
• Division of Supervision, Enforcement, and Fair Lending
(NOTE: Include a comma before “and.”)
o Midwest Region
o Northeast Region
o Southeast Region
o West Region
o Office of Fair Lending and Equal Opportunity (Fair Lending)
o Office of Enforcement
o Office of Supervision Policy
o Office of Supervision Examinations
• Legal Division (do not use Office of the General Counsel)
• Office of External Affairs
• Office of the Director
• Research, Markets, and Regulations Division (RMR)
(NOTE: Include a comma before “and.” Do not use an ampersand &.)

VI. Preferred Usage of State Abbreviations
States/Other: Use the two letter postal abbreviation.
• Alabama (AL) • Nebraska (NE)

• Alaska (AK) • Nevada (NV)
• Arizona (AZ) • New Hampshire (NH)
• Arkansas (AR) • New Jersey (NJ)
• California (CA) • New Mexico (NM)
• Colorado(CO) • New York (NY)
• Connecticut (CT) • North Carolina (NC)
• Delaware (DE) • North Dakota (ND)
• Florida (FL) • Ohio (OH)
• Georgia (GA) • Oklahoma (OK)
• Hawaii (HI) • Oregon (OR)
• Idaho (ID) • Pennsylvania (PA)
• Illinois (IL) • Puerto Rico (PR)
• Indiana (IN) • Rhode Island (RI)
• Iowa (IA) • South Carolina (SC)
• Kansas (KS) • South Dakota (SD)
• Kentucky (KY) • Tennessee (TN)
• Louisiana (LA) • Texas (TX)
• Maine (ME) • Utah (UT)
• Maryland (MD) • Vermont (VT)
• Massachusetts (MA) • Virginia (VA)
• Michigan (MI) • Washington (WA)
• Minnesota (MN) • West Virginia (WV)
• Mississippi (MS) • Wisconsin (WI)
• Montana (MT) • Wyoming (WY)

VII. Preferred Usage of Major City Names
No state name is needed with the following cities:
• Atlanta • Milwaukee
• Baltimore • Minneapolis
• Boston • New Orleans
• Chicago • New York
• Cincinnati • Oklahoma City
• Cleveland • Philadelphia
• Dallas • Phoenix
• Denver • Pittsburgh
• Detroit • St. Louis
• Honolulu • Salt Lake City
• Houston • San Antonio
• Indianapolis • San Diego
• Las Vegas • San Francisco
• Los Angeles • Seattle
• Miami
References to all other U.S. cities require the city and state.
The nation’s capital should always be referred to as Washington, D.C.

VIII. Frequently Referenced Federal Agencies
Precede the name of federal agencies with U.S. if states or local governments have a similarly
named agency. For example, use U.S Department of Justice. Spell out name of the agency with
acronym in parentheses; may use acronym in subsequent references.
Federal banking agencies: Use this term when collectively referring to the FDIC, the Federal
Reserve, and the OCC. However, do not use it when referring collectively to agencies,
including the NCUA and the CFPB.
Federal financial institution regulatory agencies: Use this term when referencing other (i.e., non-
CFPB agencies) supervisory agencies collectively, including the NCUA. However, do
not use it when referring collectively to agencies when also including the CFPB.
Federal financial supervisory agencies: Use this term when referencing the following agencies
collectively:
o Board of Governors of the Federal Reserve System (Federal Reserve or FRB)
 Do not use Fed on its own to refer to the Federal Reserve.
 When referencing one of the 12 Federal Reserve System banks, initially use
the full name of the specific Reserve Bank, with a shortened name in
parentheses; may use the shortened name in subsequent references.
• Examiners from the Federal Reserve Bank of San Francisco (San
Francisco Reserve Bank) participated in the joint examination with
CFPB examiners.
o Consumer Financial Protection Bureau (CFPB), if referring to post-July 20, 2011 date
o Federal Deposit Insurance Corporation (FDIC)
o National Credit Union Administration (NCUA)
o Office of Comptroller of the Currency (OCC)
o Office of the Thrift Supervision (OTS), if referring to pre-July 21, 2011 date.
Federal Financial Institutions Examination Council (FFIEC)
Federal Housing Administration (FHA)
Federal Trade Commission (FTC)
U.S. Department of the Treasury (Treasury)
U.S. Department of Housing and Urban Development (HUD)
U.S. Department of Justice (DOJ)

IX. Preferred Style: Matters Requiring
Attention
Examiners routinely require supervised entities to address deficiencies such as those in a
compliance management system. Examiners may also require entities to take actions to correct
and prevent violations of Federal consumer financial laws. This chapter provides writing
instructions and examples of Matters Requiring Attention, which identify matters that require
both prompt attention by the supervised entity and a written response to the CFPB from the
entity.
Examples of matters requiring action by the supervised entity include:

• absence of components of a compliance management system (CMS);
• weaknesses in CMS components;
• reimbursements or restitution to consumers;
• file searches to determine extent of an issue;
• resubmission of Home Mortgage Disclosure Act Loan Application Register (HMDA
LAR);
• development of policies and procedures to correct issues that caused the required
reimbursements or restitution, or resubmission of HMDA LARs;
• violations or issues that have not been addressed since the last examination or review;
• noncompliance with a supervisory action; or
• violations that require systemic or operational changes, such as enhanced procedures and
training to ensure correct adverse action notices are sent in a timely manner.
NOTE: The instructions in this section apply to both examination reports and supervisory
letters; however, the section discusses MRAs in the context of examination reports. Examiners
should adjust the instructions, as appropriate, for supervisory letters (for example, by making the
completion due dates and reporting dates based on the transmittal of a supervisory letter).
A. Writing Matters Requiring Attention (MRAs) – General Instructions
1. Information to include:
a. actions necessary to address violations or CMS weaknesses described in the report or
letter, and
b. completion due dates and reporting dates that are specific, realistic, and measured from
the transmittal date of the examination report
2. Placement in a Supervisory Letter or Examination Report (Report)

After the Executive Summary section, in the Matters Requiring Attention section, examiners
should describe the specific expectations for corrective action and the expected time frames
for completion and reporting.

3. Lead-in verb:
a. Start the MRA with a verb (e.g., develop, implement, review).
4. Describing the MRA

a. Write the MRA in a way that clearly connects the MRA to the related issues discussed in
the relevant Area Reviewed under Comments and Supporting Analysis.
b. Describe the MRAs in a manner that allows:
o the entity to clearly understand what corrective actions need to be taken; and
o examiners to clearly evaluate when a specific corrective action is complete.
Compare:
Improve compliance with the Equal Credit Opportunity Act and its implementing
Regulation B.
to the preferred:
Provide staff training on the Regulation B’s requirements for adverse actions,
including the requirement to provide a reason for denial in written notices.
Incorporate into the Bank’s compliance audit program a review of adverse

actions for compliance with Regulation B requirements.
c. If management completed an MRA taken during the course of the examination, list the
MRA and then indicate that it was completed during the examination.
NOTE: MRAs that were completed during the examination must be entered into SES.
5. Separate MRAs by Due Date

To the extent possible, do not combine MRAs that might be completed at different points in
time. The separation of such corrective actions will facilitate an examiner’s determination
that a specific MRA is complete and will facilitate recording in SES that a specific MRA is
complete. (It will also make it easier for the entity to determine when it has completed an
MRA.)
6. Time frames for Due Dates

MRA descriptions include two types of dates, both specified as calendar days:
• Completion due date(s): when we expect the entity to finish implementing the actions;
and
• Reporting date(s): when we expect the entity to report to the CFPB on progress and/or
completion of MRAs.
Depending on the expected action, the completion due date and the reporting date may be the
same. Alternatively, the completion due date may be some time in the future, with interim
progress reports.

When specifying time frames:
a. For completion due dates, allow sufficient time for the MRA to be implemented.
b. For reporting dates, require a generally short time frame (e.g., every three months).
c. Ensure that time frames are reasonable.
d. Base the completion due date and the reporting date on the “Transmittal Date.” Include a
footnote that states:
The Transmittal Date is the date that the CFPB emails the Report to the
supervised entity.
7. Lead in Sentences Regarding Reporting to the CFPB

Use one of the following lead in sentences.
a. This examination report includes no matters requiring corrective action.
<or>
b. This examination found matters that require a written response to the CFPB.

B. Examples - General
NOTE: The information in the examples is illustrative and may not reflect the information
included in actual MRAs resulting from examination findings.
Matters Requiring Attention
The examination found matters that require a written response to the CFPB.
Reporting date: 90 calendar days from the transmittal 1 of this Report (and every 90 calendar
days thereafter until the MRA completion date), provide the CFPB progress reports on fulfilling
the following MRAs. Include in the reports details on the steps taken to complete the MRA(s)
and the results of the steps taken.
Area Reviewed: Mortgage Origination – Affiliate Marketing Opt-out Notices
1. Review accounts of customer whose mortgage loans originated in the past 12 months to
determine which customers did not receive affiliate marketing opt-out notices. For
customers who did not receive the opt-out notices, send the opt-out notices.
Completion due date: 90 calendar days from the transmittal of this Report.
2. Review the accounts of customers who did not receive opt-out notices to determine
whether the entity used the eligibility information about the consumer for affiliate
marketing purposes. For any such accounts identified, immediately cease such affiliate
marketing.
3. Revise policies and procedures to reflect Regulation V’s affiliate marketing requirements.
Area Reviewed: Credit Cards – Error Resolution

4. Revise policies and procedures to ensure compliance with Regulation E dispute and error
resolution requirements.
Completion due date: 90 calendar days from transmittal of this Report.
1
The Transmittal Date is the date that the CFPB emails the Report to the supervised entity.

C. MRAs Instructions - Compliance Management Systems
When writing MRAs for compliance management systems where there is no related violation of
law:
• Keep MRAs at a high level with a focus on improving a compliance management system.
• Do not direct the entity to do specific things to address weaknesses as it is the board of
directors’ and management’s responsibility to determine the specific steps necessary to
effect change.
NOTE: The examples on this page do not include time frames for completion or reporting.
Compare (underlined text highlights language that may be considered too specific):
Evaluate the staffing needs of the institution’s compliance management department.
Provide the CFPB a written document that details the institution’s staffing plans. Include
the identified needed staffing positions, the required experience, and the staffing
numbers. Provide the proposed job descriptions and time frames for posting and filling
the positions.
to the preferred:
Evaluate the staffing needs of the institution’s consumer compliance management

department. Provide a written plan describing the steps that the institution will take to
ensure that consumer compliance management positions are filled with a sufficient
number of qualified individuals.
***
Compare:
Ensure that the board is apprised of matters related to Federal consumer financial laws
and consumer risks through regular and detailed discussions at board and committee
meetings, and inclusion of appropriate materials in board packages.
to the preferred:
Ensure that the board is apprised of Federal consumer financial laws and consumer risks
through regular and detailed discussions at board and committee meetings.

D. Examples - MRAs for Compliance Management Systems (with no related
violations)
Area Reviewed: Compliance Management Systems
Board and Management Oversight
1. Evaluate the staffing needs of the institution’s consumer compliance management
department and develop a plan that ensures consumer compliance management positions
are filled with a sufficient number of qualified individuals.
2. Implement the plan that ensures consumer compliance management positions are filled
with a sufficient number of qualified individuals.
Completion due date: One year from transmittal of this Report.
3. Take measures to ensure that the board is apprised of matters related to Federal consumer
financial laws and consumer risks through regular and detailed discussions at board and
committee meetings.
Policies and Procedures

4. Ensure that policies and procedures for all consumer financial products or services
offered by the institution address compliance with all applicable Federal consumer
financial laws in a manner designed to prevent violations and to detect and prevent
associated risk of harm to consumers.
5. Ensure that the policies and procedures are maintained and modified regularly to remain
current and to serve as a reference for employees in their day-to-day activities.
Completion due date: Two years from transmittal of this Report.
2

Monitoring and Corrective Action
6. Develop a system of risk-based, periodic reviews in order to monitor whether
transactions and other consumer contacts are handled in accordance with Federal
consumer financial laws and with the institution’s own policies and procedures. Develop
a system that will ensure that, when necessary, timely corrective action is taken and,
when appropriate, findings are escalated to management and the board.
7. Implement the system for monitoring, timely corrective action, and reporting to
management and the board.
Training
8. Develop an improved consumer compliance training program that is current, complete,
effective, and commensurate with the institution’s size and risk profile. The training
program is expected to be directed to appropriate individuals based on their roles, and
include not only regulatory requirements imposed by Federal consumer financial laws,
but also the institution’s specific consumer compliance-related policies and procedures.
9. Implement the improved consumer compliance training.
Consumer Complaint Management

10. Develop policies and procedures to ensure that, regardless of the channel through which
the customer enters the complaint:
o all complaints received are reviewed for possible regulatory violations;
o all complaints are resolved properly; and
o complaint information is organized, retained, and used as part of the Bank’s
compliance management system.
11. Implement policies and procedures to improve consumer complaint management.
compliance management system.

Compliance Audit
12. Ensure that the compliance audit program addresses compliance with all applicable
Federal consumer financial laws.
13. Develop an audit schedule and scope that is appropriate for the institution’s size, its
consumer financial product offerings, and the manner of conducting its consumer
financial products business.
14. Ensure that audit coverage extends to all lines of business that offer consumer financial
products and services, including any new consumer financial products or services that the
institution implements.
Service Provider Oversight

15. Revise the existing Service Provider Management Policy to ensure that it evaluates
providers for consumer compliance risks.
16. Implement the revised Service Provider Management Policy to ensure that service
providers operate in compliance with Federal consumer financial laws, and that vendor
management due diligence efforts are effectuated and documented appropriately.

D. Examples – HMDA
Example 1 - Matters Requiring Attention – Resubmission required

Area Reviewed: Regulation C Compliance Review
1. Review, correct, and resubmit the 2011 Home Mortgage Disclosure Act Loan
Application Register.
2. Develop a plan, approved by the board of directors, to address the high HMDA error
rates cited in this Report and provide the plan to the CFPB. The plan must include steps
to:
a. improve the accuracy of data input by implementing the necessary controls,
b. establish and implement policies and procedures for accurate HMDA data
entry and audits,
c. monitor and test for data accuracy on a quarterly basis, and
d. train all affected employees on a periodic basis.
3. Implement the plan to address the high HMDA error rates.
3

Example 2 - Matters Requiring Attention – Resubmission required and
potential enforcement action anticipated

1. Review, correct, and resubmit the entire Home Mortgage Disclosure Act Loan
Application Register for the calendar year 2011.
The HMDA violations identified in the course of the examination, any additional violations that
might be identified, and any additional corrective action will be addressed separately from this
Examination Report.
4

X. Preferred Style: Violations
A. Violations of statutory and regulatory requirements
When examiners find violations of Federal consumer financial laws during an examination or
review, examiners must relay information about the violation in a manner that allows the
supervised entity to understand clearly:
a. the legal requirements,

b. the entity’s practice that violated legal requirements, and
c. the root cause of the violation, tying it to weaknesses in some aspect of a compliance
management system.
Examiners should include any response from management or commitment by management to

take corrective actions. The following discussion outlines the preferred method for writing
violations in an examination report or supervisory letter.
The write-up of a violation should include the following (examples are included in section C and
D):
Area Reviewed: [insert Institution Product Line]
Conclusion
a. Include a conclusion statement about the violation, including a statutory or regulatory cite
for each violation.
b. Include a phrase summarizing the statutory or regulatory requirements (e.g., use the title
of the subsection of the law, or a variation thereof, as the examples below illustrates).
c. Do not describe violations or requirements of law as “technical.”
d. If a statute’s provisions have been implemented by a regulation, only cite the section of
the regulation that was violated; do not cite the U.S. Code section for a statute (however,
in such cases, include the name of the statute).
The Bank violated the Truth in Savings Act’s periodic statement disclosure requirements
for overdraft services as implemented by Regulation DD (12 CFR 1030.11(a)).
The Bank violated 12 CFR 1005.11’s required procedures for resolving errors in
electronic fund transfers, as required by Regulation E, the implementing regulation for
the Electronic Fund Transfer Act.
Comments and Supporting Analysis

a. Describe what you reviewed. Include number of loans reviewed, number in universe, and
whether sampling was statistical or judgmental, as appropriate.
b. Describe in greater detail the statutory or regulatory requirements in order that all readers
of the examination report or supervisory letter, including a board of directors who may

not have detailed knowledge of legal requirements, are able to fully understand the
requirements.
HINT: You may copy the statutory or regulatory language. If the legal language is
lengthy, paraphrase the legal requirement.
c. Describe what the supervised entity was doing (or not doing); make a clear connection
that the practice was not adhering to the law.
d. Describe the root cause of the violation, tying it to weaknesses in one of the components
of a compliance management system.
e. As applicable, describe management’s response and management’s responsible party. If

management disagrees with examiners’ findings, briefly state this fact.

B. Unfair, Deceptive, or Abusive Acts or Practices
Before beginning to draft findings of unfair, deceptive, or abusive acts or practices (UDAAPs),
examiners should discuss the write-up with their Headquarters Office of Supervision Policy
point-of-contact (Policy POC). Such descriptions of findings will require a different style than
those involving laws and regulations that prescribe specific requirements.
UDAAP write-ups will generally focus on the standards that must be met for a finding of
unfairness, deception, or abusive practices. Examiners should describe the entity’s relevant acts
or practices (or omissions) using the related standard language below. Before a report is issued,
the Legal Division must review the report (the Policy POC will facilitate the Legal Division’s
review).
Unfair
The standard for unfairness is:
1. The act or practice must cause or be likely to cause substantial injury to consumers;
2. Consumers must not be reasonably able to avoid the injury; AND
3. The injury is not outweighed by countervailing benefits to consumers or to competition.
Deceptive
The standard for deception is:
1. There must be a representation, omission, act, or practice that misleads or is likely to
mislead the consumer;
2. The representation, omission, act, or practice must be considered from the perspective of
the reasonable consumer; AND
3. The representation, omission, or practice must be material.
Abusive
Section 1031 of the Dodd-Frank Act gave the CFPB the authority to declare an act or
practice abusive in connection with the provision of a consumer financial product or service
if the act or practice:
1. materially interferes with the ability of a consumer to understand a term or condition of a
consumer financial product or service; or
2. takes unreasonable advantage of:
a. a lack of understanding on the part of the consumer of the material risks, costs, or
conditions of the product or service;
b. the inability of the consumer to protect the interests of the consumer in selecting or
using a consumer financial product or service; or
c. the reasonable reliance by the consumer on a covered person to act in the interests of
the consumer.

UDAAP - General instructions for Examination Reports and Supervisory
Letters
Only list UDAAP as an Area Reviewed IF the CFPB’s UDAAP examination procedures were
completed. Do NOT list UDAAP as an Area Reviewed if examiners merely kept a look out for
potential acts or practices that might need a thorough review using the UDAAP examination
procedures.
Do NOT say that examiners reviewed whether an entity was “in compliance” with the unfair,
deceptive, or abusive acts or practices provision of the Dodd-Frank Act. Instead, say that
examiners reviewed whether the entity “engaged in” unfair, deceptive, or abusive acts or
practices.

C. Violation Examples - General
Example 1
NOTE: The information in the examples is illustrative of describing a violation of law. The
examples may not reflect all the information that would be included when writing up the Area
Reviewed sections. Further, actual reports may have referenced certain terms (such as the
Gramm-Leach-Bliley Act in the example below) earlier in the report; in such cases, the acronym
(e.g., GLBA) may be used in the Area Reviewed section that describes the violation.
Area Reviewed: Credit Cards
Conclusion
The Bank violated 12 CFR 1016.5(a)(1) by failing to deliver annual privacy notices as
required by the Gramm-Leach-Bliley Act’s implementing Regulation P (Privacy of
Consumer Financial Information).
Section 1016.5(a)(1) of Regulation P requires a financial institution to provide a clear

and conspicuous notice to customers, that accurately reflects its privacy policies and
practices, not less than annually during the continuation of the customer relationship.
In reviewing a sample of 30 privacy notices, examiners found that 10 credit card members
who completed a notice of address change did not receive billing statements and other
communications, including the required privacy notices. The violations resulted from
technical changes made on January 1, 2012, to the entity’s information management
system that generates billing statements and privacy notices. The technical changes failed
to reflect changed addresses. The violations evidence weaknesses in the monitoring of
system changes by failing to evaluate and test technical changes before implementation.
Management agreed with the violations and, during the examination, corrected the Bank’s
practices. Examiners reviewed a listing of affected card members and actual examples of
subsequent mailings of privacy notices and determined that the Bank had implemented
practices to prevent future violations.

Example 2
Reviewed sections. Further, actual reports may have referenced certain terms (such as the Real
Estate Settlement Procedures Act in the example below) earlier in the report; in such cases, the
acronym (e.g., RESPA) may be used in the Area Reviewed section that describes the violation.
Area Reviewed: Mortgage Origination
Conclusion
The Bank has an adequate compliance management system that minimizes the occurrence of
violations of Federal consumer financial laws for mortgage origination activities.
Nevertheless, examiners found violations of the following provisions of the Real Estate
Settlement Procedures Act’s implementing Regulation X:
• 12 CFR 1024.17(g) - requirements for Initial Escrow Account Statements
• 12 CFR 1024.8(b) - requirements for the use of HUD-1 or HUD-1A settlement
statements
Each year the Bank reviews its product offerings, policies, and procedures to assess its ability
to adhere to Federal consumer financial laws. This assessment includes updating policies
and procedures to reflect new regulations, guidance, and interpretations. The Bank also
conducts transaction testing and external reviews to determine the effectiveness of its internal
controls. This testing is comprehensive and generally effective. However, the review of
mortgage lending revealed the following violations:
Section 1024.17(g)(1)(i) of Regulation X requires that after conducting the escrow account
analysis for each escrow account, the servicer submit an initial escrow account statement
to the borrower at settlement or within 45 calendar days of settlement for escrow accounts
that are established as a condition of a loan.
(i) The initial escrow account statement shall:
• include the amount of the borrower's monthly mortgage payment and the
portion of the monthly payment going into the escrow account;
• itemize the estimated taxes, insurance premiums, and other charges that the
servicer reasonably anticipates to be paid from the escrow account during the
escrow account computation year and the anticipated disbursement dates of
those charges;
• indicate the amount that the servicer selects as a cushion; and
• include a trial running balance for the account.

In eight out of 50 residential real estate loans reviewed, examiners found that the initial
escrow analysis was incorrect. The second tax payment for the upcoming 12 month period
was not disclosed in the initial escrow account analysis; consequently the cushion, initial
deposit, and aggregate adjustment were incorrect. The violations were attributed to one
customer representative who was unaware of the Regulation X requirements, evidencing
weaknesses in the entity’s training staff on the legal requirements that are pertinent to their
job responsibilities. In addition, the violations evidence the lack of procedures (e.g., job
aids) to assist customer representatives’ complying with regulatory requirements.
Management agreed with the violation. The Bank sent corrected disclosures to the
borrowers; therefore, additional corrective actions are not necessary.
Section 1024.8(b) of Regulation X requires the settlement agent to complete the HUD–1 or
HUD–1A, in accordance with the instructions set forth in Appendix A of Regulation X (12
CFR Part 1024). The loan originator must transmit to the settlement agent all information
necessary to complete the HUD–1 or HUD–1A.
For all 10 residential real estate loans reviewed, examiners found that the Bank failed to
properly disclose the correct amount of reserves in the aggregate adjustment section (line
1000) on the HUD-1 settlement statement. The Bank used one extra month in the calculation
of the amount of taxes for the aggregate adjustment. The cause of the violation was
attributed to an error in the information management system used to generate the HUD-1s.
The violations evidence weaknesses in monitoring systems to ensure compliance with legal
requirements. While the aggregate adjustment was not calculated correctly, it should be
noted that the disclosed initial deposit required of the customer and the amount that was
actually collected from the borrower were correct. Therefore, this error did not have an
adverse impact on borrowers.

Example 3
Electronic Fund Transfer Act in the example below) earlier in the report; in such cases, the
acronym (e.g., EFTA) may be used in the Area Reviewed section that describes the violation.
Area Reviewed: Overdraft Protection Products
Conclusion
The Bank violated the error resolution requirements, covering time limits and investigations,
of the Electronic Fund Transfer Act’s implementing Regulation E (12 CFR 1005.11(c)(2)).
Section 1005.11(c)(2) of Regulation E provides that in the event that an institution is

unable to complete an investigation of an alleged EFT error within 10 business days of
notice from the consumer, an institution may take up to 45 days from the receipt of the
notice of error, provided that it provisionally credits the consumer’s account in the amount
of the alleged error within 10 business days of receiving the notice of error. In these cases,
the institution must:
• inform the consumer within two business days of the provisional crediting,
notifying them of the amount and date that the credit was given, and
• give the consumer full use of the funds during the remainder of the investigation.
Further, the institution must then:

• correct the error within one business day after determining that an error occurred,
and
• must report the results of the investigation to the consumer within three business
days after completing the investigation.
During the examination, a total of 99 disputes were reviewed by examiners. In four of the 99
disputes, examiners found that the Bank provided provisional credit outside of the 10
business day window prescribed by Regulation E. These cases were discussed with
management, who acknowledged that provisional credit had been given outside of the
required time frame.
These violations stem from the fact that the Bank’s current practice is to begin the error
investigation upon receipt of a completed and signed dispute form, instead of beginning the
investigation immediately upon oral communication of an issue from a consumer. Though
the Bank’s written procedures explain that the investigation time frame begins upon oral
notification, in practice, investigations do not begin until written confirmation of the error is
received. In some cases, written receipt of the error may be received several days after oral

notification, causing the investigation time frames to become protracted. This was the case
in the four instances noted above, where provisional credit was provided later than 10
business days from receipt of notice from the consumer. It is noteworthy that this delay in
the start of the investigation was also noted in a previous examination by the Bank’s prior
federal supervisor, and in recent compliance audits, but had not been properly addressed in
either case, leading to the violations found during our review. The violations evidence
weaknesses in the entity’s monitoring and corrective action processes.
Management explained that they are in the process of revamping their Regulation E error
resolution process, which includes the development of a new automated system for the
reporting and tracking of disputes. Management indicated that the new system will allow for
disputes to be immediately documented upon oral notification, which they believe should
eliminate the time delay between oral notification, written confirmation of the error, and the
start of the investigation. Management expects the new system to be up and running within
120 days.

D. Examples – HMDA Violations
Home Mortgage Disclosure Act in the example below) earlier in the report; in such cases, the
acronym (e.g., HMDA) may be used in the Area Reviewed section that describes the violation.
NOTE: Only one of the following examples would be applicable to a particular report.
Example 1. No HMDA Errors, or HMDA errors observed below CFPB

resubmission threshold
Conclusion
Examiners reviewed a sample of the Bank’s Home Mortgage Disclosure Act Loan Application
Register (HMDA LAR) and found no violations of HMDA or Regulation C (12 CFR Part 1003).
Management has adopted policies and procedures to ensure HMDA data integrity.

We reviewed the Bank’s policies, procedures and training materials related to the collection and
reporting of HMDA data. The Bank reviews all business lines annually to ensure that all
covered loans are included in the HMDA LAR. The Bank provides annual training on HMDA
compliance to all employees involved in collecting and reporting HMDA data. In addition, the
Enterprise Compliance Department performs monthly LAR accuracy testing and provides
written reports to the Chief Compliance Officer.
We verified the Bank’s 2012 HMDA LAR by reviewing the data for 32 randomly selected files.
We identified one record in which the loan purpose was incorrectly coded as home improvement
instead of refinance. We determined that this was an isolated instance in coding the loan in the
Bank’s systems.

Example 2a. Resubmission required

Conclusion
We identified errors on the Bank’s 2011 Home Mortgage Disclosure Act Loan Application
Register (HMDA LAR), in violation of HMDA’s implementing Regulation C (12 CFR
1003.4(a)). These errors exceed the CFPB’s resubmission thresholds.

Section 1003.4(a) of Regulation C requires that mortgage-lending institutions collect data
regarding applications for, and originations and purchases of, home purchase loans, home
improvement loans, and refinances for each calendar year.
We reviewed 79 loan files from the Bank’s 2011 HMDA LAR and identified 32 records
containing one or more errors, a 40.5 percent sample error rate. The data fields containing the
largest number of errors were action date (17) and application date (15). Additional errors were
identified in the loan amount and income fields. While some errors appeared to be isolated,
others, such as those in the application date and action date, were recurring. The errors are
attributed to weaknesses in training staff in Regulation C requirements and to weaknesses in
monitoring and taking corrective actions.
The Bank provided a written response admitting that 20 of the HMDA LAR entries had errors,
but challenging the errors that the examination team identified in the additional 12 entries. We
fully considered the Bank’s responses and concluded that two entries were not errors; however,
the other 10 were errors.
In 17 files, examiners determined that the Bank stated the action date incorrectly on the HMDA
LAR. Based on documents found in the loan files, the action date that was listed on an internal
Withdrawn/Denied form was not the date found on the HMDA LAR. The differences between
the reported and actual dates varied from one day up to up to three months.
In 15 files, examiners determined that the Bank stated the application date incorrectly on the
HMDA LAR. Based on documents found in the loan files, the application date was not the date
found on the HMDA LAR. The differences between the reported and actual action dates varied
from 10 days to up to three months.
In seven files, examiners determined that the loan amount stated on the HMDA LAR was
inaccurate. The differences between the reported and actual loan amounts varied from $500 to
several thousand dollars. Management indicated that the larger variances were due to changes in
the amounts due to collateral values, but the loan documentation did not support these changes.

In five files, examiners determined that the HMDA LAR entry for income was inaccurate. It
appears that the income reported on the HMDA LAR was not the income used in the final
underwriting decision.

Example 2b. Resubmission required

Conclusion
We identified errors on the Bank’s 2011 Home Mortgage Disclosure Act Loan Application
Register (HMDA LAR), in violation of HMDA’s implementing Regulation C (12 CFR 1003.4).
These errors exceed the CFPB’s resubmission thresholds.
Despite multiple prior citations of inaccurate HMDA data by its prudential regulator, the Bank
continues to submit inaccurate HMDA data. The Bank has not developed or implemented the
necessary policies and procedures to ensure timely submission of accurate data.

Section 1003.4(a) of Regulation C requires that mortgage-lending institutions collect data
regarding applications for, and originations and purchases of, home purchase loans, home
improvement loans, and refinances for each calendar year.
Over the past several years, the Bank has failed to comply with HMDA and Regulation C’s
requirements to compile accurate loan data. Further, the Bank continues to have no formal
policies and procedures, training program, or process for conducting compliance audits of its
HMDA practices, all of which are components of a compliance management system.
The Federal Reserve Bank of New York identified HMDA data integrity failures during its
previous two examinations, citing widespread HMDA violations in the Bank’s 2008, 2009, and
2010 HMDA LARs. The Federal Reserve’s Examination Reports dated May 1, 2009, and June
10, 2011 both included citations and corrective actions related to the Bank’s weak HMDA
compliance. Despite these past findings, errors persist.
In 2011, the Bank’s HMDA submission included 15,588 mortgage applications. Of these
applications, 9,557 were reported as originated; 888 as approved but not accepted; 1,267 as
withdrawn; 2,843 as denied; and 1,033 as closed for incompleteness.
In this current examination, CFPB examiners reviewed a sample of 2011 LAR, including 79 loan
applications: 33 were reported as originated; 20 as withdrawn; six as denied applications; and 20
as closed for incompleteness. Of the 79 loan files sampled, examiners identified at least one
error in each of 36 loan files, resulting in a high error rate of 45.6 percent. Examiners noted the
inaccurate date in the following fields:
• Action Taken;
• Type of Purchaser of Loan (the type of entity purchasing the loan within the same
calendar year);
• Loan Amount (in thousands); and
• Gross Annual Income (in thousands, relied on in processing the application).

In 16 files, examiners determined that the Bank incorrectly stated the action taken on the HMDA
LAR. Based on documents found in the loan files, the action taken that was listed on an internal
Withdrawn/Denied form was not the action taken found on the HMDA LAR.
In 21 files, examiners determined that the type of purchaser of the loan was coded incorrectly as
“other type of purchaser” on the HMDA LAR. The Bank incorrectly coded each loan it
originated and closed in its own name as “other type of purchaser” regardless of whether the loan
was sold within the same calendar year. The applicable code identifying the type of entity
purchasing the loan, as defined in Appendix A to Part 1003 of Regulation C, must be chosen
when the loan originated was then sold within the same calendar year.
In nine files, examiners determined that the loan amount stated on the HMDA LAR was
inaccurate. The differences varied from $500 to several thousand dollars. Management
indicated that the larger variances were due to changes in the amounts due to collateral values,
but the loan documentation did not support these changes.
In one loan file, examiners determined that the HMDA LAR entry for gross annual income of the
applicant was inaccurate. It appears that the income reported on the HMDA LAR came from
documentation in the file, which was not used to document the final underwriting decision.
The Bank’s procedures for HMDA input and validation are not commensurate with its size and
complexity. For several years, the Bank’s prudential regulator has directed the Bank to
implement procedures to improve HMDA data integrity. Previous Federal Reserve Examination
Reports addressed the need for the Bank to implement procedures to correct previous HMDA
data errors. The persistence of HMDA data errors in spite of the repeated notification requires
corrective action.

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The CFPB Supervision Style Guide

How to Use this Guide

About the Style Guide

NOTE: Updates to the Style Guide are highlighted in yellow.

The Style Guide is broken down into several:

The CFPB Supervision Guide is based on the CFPB’s Style Guide

CFPB Supervision Style Guide (May 2014) 1

The CFPB coordinated supervisory reviews of AMEX FSB and AMEX

To make an abbreviation plural, add a lowercase “s”:

CFPB Supervision Style Guide (May 2014) 2

The examiner discovered incorrect disclosures at the ATM.

The Bank was previously examined by the OCC.

We found no violations of HMDA and ECOA.

Avoid using acronyms that are not in common usage. Compare:

The Bank does not offer deposit-advance products.

addendum Plural is addenda.

ad hoc In general, italicize anything in a foreign language, including Latin.

adjustable-rate, Use hyphen when used as a compound adjective.

Use two words and no hyphen when rate is used as a noun.

African Preferred to Black when referring to a racial characteristic protected against

When used as a noun, do not hyphenate.

When used as an adjective, hyphenate African-American.

agree to, Agree to means to give assent.

CFPB Supervision Style Guide (May 2014) 3

a.m., Use lowercase and periods.

appendix(ces) Capitalize when referring to a specific appendix.

affect, Affect, usually used as a verb, means to influence or change.

Affect can also mean to act in a way you do not feel.

Effect, usually used as a noun, means a result.

assure, Assure means to give confidence to.

Ensure means to make certain. It is normally followed by that.

CFPB Supervision Style Guide (May 2014) 4

NOTE: The examples in the Supervision Style Guide capitalize Bank

Use it when referring to a singular bank. Do not use they.

When referring to multiple banks, use they.

bill pay, Use hyphen when used as a compound adjective.

Use two words and no hyphen when used as a noun.

Bank of America’s Board of Directors responded to the CFPB

cash flow Two words.

CFPB Supervision Style Guide (May 2014) 5

Use lowercase in all other uses.

compliance audit When describing one of the components of a compliance management

Avoid using internal audit or quality control when discussing a

However, when discussing a specific program of an entity, use the term

West Bank’s Office of Compliance Management System is new.

CFPB Supervision Style Guide (May 2014) 6

cost-effective Use hyphen.

data-driven Use hyphen.

decision-making Hyphenate when used as a compound modifier, as in decision-making

CFPB Supervision Style Guide (May 2014) 7

depository Use depository institution when referring to banks, savings associations,

Use it when referring to a singular depository institution. Do not use they.

When referring to multiple depository institutions, use they.

Differ with means to disagree.

downpayment One word.

due diligence Two words.

CFPB Supervision Style Guide (May 2014) 8

I like root vegetables; i.e., the ones that grow underground.

HINT: Both e.g. and example begin with the letter e.

email Use lowercase and no hyphen.

etc. Always use as an abbreviation; do not use etcetera. Do not italicize.

examination Use examination when referring to a point-in-time examination where

Do not use exam.