Our Services

CFPB Compliance Documentation Review & Gap Analysis

How we do it

Astra has assessed its own compliance management systems, including its internal controls policies and procedures, for its debt collection business.

Step 1
Is to identify acts or practices that materially increase the risk of violations of Federal consumer financial laws.
Step 2
Is to gather facts that help to determine whether acts or practices violate the requirements of Federal consumer financial laws.
Step 3
Is to take corrective action and implement as appropriate further internal controls, policies and procedures.

A typical CFPB compliance audit addresses applicability to and compliance with the seven (7) modules of the CFPB Examination Procedures (“Examination Procedures”) as listed below:

  • Entity Business Model.
  • Communications in Connection with Debt Collection.
  • Information Sharing, Privacy, and Interactions with Consumer Reporting Agencies.
  • Consumer Complaints, Dispute Resolution, and Debt Validation.
  • Payment Processing and Account Maintenance.
  • Equal Credit Opportunity Act.
  • Litigation Practices, Repossession, and Time-Barred Debt.

What we do

Astra’s trained Audit Consultants review our clients' Compliance Management System documentations that focus on these compliance areas and include the following services

  • An analysis of provided documents to determine gaps in CFPB compliance documents and those maintained by the agency.
  • A review of CFPB compliance documents to gauge compliance with the Examination Procedures requirements.
  • A remediation report from Astra detailing any deficiencies requiring correction and/or explanation.
  • A review of the agency’s remediation plan and corresponding documents.

In addition to the above-referenced services and scope, Astra offers the following services

  • Compliance Document Editing - With agency prior approval and feedback where necessary, Astra will make the necessary changes to the documents provided, so that they meet or exceed minimum expected requirements of the CFPB.
  • Compliance Document Drafting - Upon completion of the above Gap Review, and with agency prior approval and feedback where necessary, Astra will draft compliance documents that BQ Law does not currently have documented.
  • CFPB Compliance Manual - Upon completion of Phase Two and the Audit-Related Services, Astra will create an agency, tab-divided CFPB compliance manual which will include the Astra audit and agency compliance documents.

Records under review are as follows

  • Organizational charts and process flowcharts.
  • Board minutes, annual reports, or the equivalent to the extent available.
  • Notes and disclosures.
  • Third-party contracts and oversight materials, including monitoring reports and findings.
  • Relevant management reporting.
  • Policies and procedures.
  • Compensation policies.
  • Operating checklists, worksheets, and review documents.
  • Monitoring procedures.
  • Consumer files, including original loan documents, and payment records systems.
  • Historical examination information.
  • Audit and compliance reports, and management responses to findings.
  • Training programs and materials.
  • Scripts for employee use.
  • Telephone recordings.
  • Written correspondence with consumers.
  • Relevant computer program and system details.
  • Court documents; and.
  • Consumer complaints and disputes, including those submitted to CFPB Consumer Response Center, Consumer Sentinel, the Better Business, CFPB, or other sources as appropriate.
Astra is deeply committed to its approach of promoting a healthy business environment for its clients. We pride ourselves on understanding and analyzing the requirements