Beware of PARRs: CFPB’s Revisions to its Appeals Process
The revised appeals process does not permit an appeal of adverse findings related to a recommended or pending investigation or public enforcement action until the investigation or action has been resolved. This highlights the importance of preparing a compelling response to notices of Potential Action and Request for Response letters, which the bureau sends out after an examination to inform the financial institution it is considering taking supervisory action. [11/16/15]