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Credit unions that make student loans should note that the Consumer Financial Protection Bureau on Monday released the procedures it will be using in its examinations of student lenders.

The procedures are an extension of the CFPB's general supervision and examination manual and will be used as a field guide by examiners to ensure that private student lenders are in compliance with federal consumer financial laws, the agency said. Under the Dodd-Frank Act, the bureau has the authority to supervise large banks, as well as nonbanks, that make private student loans.

The CFPB says that examiners will be assessing whether student lenders have the appropriate processes in place to prevent harm to borrowers. More specifically, examiners will be looking to verify that lenders are:

• using accurate, nondiscriminatory advertising or marketing;
• providing the appropriate disclosures about loan costs and terms;
• providing accurate information; and
• adequately handling borrower inquiries and complaints.

The CFPB also noted that the examination process will be "an ongoing process of pre-examination scoping and review of information, data analysis, onsite examinations, and regular communication with supervised entities, as well as follow-up monitoring." The bureau also said that examiners will coordinate and work closely with the CFPB's enforcement staff to take appropriate enforcement actions to address harm to consumers when necessary.

NAFCU continues to be concerned about the breadth and scope of the CFPB's supervision, which appears to exceed what is mandated by the Dodd-Frank Act.

• CFPB student lending examination procedures
• CFPB supervision and examination manual