Cordray is now in full gear. He is going around the country holding town halls and is on the internet asking the public to send their complaints to him. This is designed to elicit areas of focus and perceived “unfair” practices in all areas of lending and servicing. The public, of course, is happy to tell stories of how they are being charged too much for overdrafts, credit cards, and the like. One thing a politician needs to do is respond to a lot of complaints to make it look like he is doing something for the constituents. That means Cordray will need to act against some lenders this year so Obama can say look what he is doing the protect the “hard working Americans” who are being abused by the big bad banks.

While this is happening he is sending his teams of examiners into all the larger lenders to find “abusive and unfair” practices. By starting at the biggest, he is hoping to see what the big lenders who can afford armies of lawyers and compliance people are doing, and then he will go to the smaller lenders and claim they are not doing it right. For the big banks and non bank lenders, this is not a major problem since they are most likely already in compliance to a great degree. For the small players, even if they are trying, they will not be in full compliance on something since the cost to do so is prohibitive. These teams just appear and they not only go through all of the policies and manuals, they actually listen in on calls to consumers to find someone saying something that is perceived by the examiner to be misleading or unfair. This is a major departure from past examinations where the review was of policies and procedures, and not intrusive on calls.

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