Twas the Night Before the Examiners

'TWAS THE NIGHT BEFORE THE EXAMINERS

'Twas a bright Monday morning and all through the bank,

We awaited the examiners, our spirits were dank,

The policies were bound in a book with great care,

Now all we could do was just mutter a prayer.

The staff was so nervous just thinking of Feds,

While visions of violations danced through their heads.

With the Chairman in Vegas, the President in Vail,

Would they come back to find us in jail?

When out in the lobby there arose such a clatter,

We sprang from our desks to see what was the matter.

And what to our unlucky eyes should appear,

But a man with a badge and eight of his peers.

With computers and briefcases and faces so numb,

We knew in a flash that our time had just come.

More rapid than soldiers he filed in his clan,

And he gathered them all in an office to plan.

"Be picky, be thorough, be tough, use your weight,

To let them all know you have control of their fate.

To Credit, to Audit, go make them feel small,

Now dash away, dash away, dash away all."

And then in a twinkling we heard through the door,

The sharpening of dozens of claws on the floor.

And as the door opened, our eyes grew quite large,

Out came the head honcho, the Examiner-in-Charge.

He was dressed up like Rambo, from his head to his feet,

He looked like he craved a good piece of raw meat.

A bundle of printouts he held close to his chest,

For two long weeks the copier would not rest.

His eyes did not twinkle; his brows did not bend,

Is there anyone out there this man could call friend?

He was calm and collected, so passive and cold,

He backed down to no one but God we are told.

The stub of a pencil he held tight in his teeth,

From his belt hung a calculator tucked in a leather sheath.

But first to the break room to fill up his large belly,

Free coffee and soft drinks and donuts with jelly.

He'd work for an hour and then break for some lunch,

Where he went for two hours, we don't have a hunch.

For the rest of the day he would talk on the phone,

And tie up the line 'til the time to go home.

For weeks this routine just seemed to drag on,

When finally his troops had even all gone.

And then the day came when he said we should meet,

We entered "his" office; he said "take a seat."

Regs have all changed, your policy stinks,

Our file samples should be doubled methinks.

Looking at HMDA, it's not your best year,

You need creative underwriting, it's all crystal clear.

Your Reg. DD schedule is wrong; you must cut your fees,

What do you mean who is TiLA, rethink your compliance strategies.

But what we won't stand for is legal infractions,

If you don't add controls, we could take further actions.

Now don't feel so badly, such problems aren't rare,

But I still feel impelled to give you a good scare."

He spoke no more words, but walked straight out the door,

We followed him wondering if he would be telling us more.

He then shook his finger at us from afar,

And nodding his head he got into his car.

And we heard him exclaim as he opened a beer,

"You passed your exam; I'll see you next year!"

Whistleblower

“Do you have information about a company that you think has violated federal consumer financial laws? Are you a current or former employee of such a company, an industry insider who knows about such a company, or even a competitor being unfairly undercut by such a company? If so, the CFPB wants to hear from you.”
- Recent CFPB blog post.

Like a siren’s song, the lure of tips from a whistleblower has sunken many a governmental investigatory ship. A scene like this will be sure to follow the CFPB’s post.

This is the city. There are thousands of stories here, and this is one.

It’s a rainy night in the big city. Under a dimly lit streetlight in the bad part of town, two characters in trench coats meet. One is nervous, chain-smoking, oblivious to the downpour. The other is me. I work here. I carry a badge and work for the CFPB. My name is Thursday.

“Psst. Thursday?”

“No, it’s Wednesday, why do you ask?”

“No, are you Thursday, the guy I talked to on the phone? I’ve some news for youse.”

“Oh. Yes, I’m Thursday. What do you have? Just the facts.”

“I hoid that Wurst National Bank sometimes pays customers into overdraft status and then charges them a fee for doing so.”

“You don’t say.”

"Yeah, and that’s not all. Some of them fat cat bankers have been seen driving new Lincolns. I think the bank is making a profit”

“What? Are you sure about this?”

“I seen it with my own eyes. I even got a free checking account there to see if it was true. I wrote a check when I didn’t have no money in the account, and they charged me a fee.”

“Was it reasonable? Was it representative of the actual cost to the bank for handling an NSF item or was it exorbitant, indicating unfair, deceptive, and abusive acts and practices? You know, UDAAP.”

“Huh?”

“Never mind. How much was the fee?”

“5 fins. $25 clams.”

"Huh?"

"$25."

“Those lowlifes! Don’t they know that you are underemployed due to the failed economic policies of Reganites and can’t afford the luxury of paying a fee for simply overdrawing your account, even though it was intentional?”

“Huh?”

“Never mind. What else you got for me?”

“Well…they gave me a toaster for opening the account, but it’s only a two-holer and a bagel won’t fit in it.”

“I knew it! I’m taking down those crooks. When bankers start handing out free toasters and without considering that you might need a bagel toaster for toasted bagels to go with your morning espresso, that makes my blood boil.”

“What are you going to do, Thursday?”

“Enforcement; outreach to civil rights, community, and industry groups; and consumer education and engagement. That’s what I do. Those bums will never know what hit them.”

“So, like is there a reward or something in this for me? You know I put myself out there for you. I might not be able to open another free account for six months.”

“Don’t worry, buddy. The CFPB will get you a new ID. We have ways of going around the CIP rules.”

“Great! I gotta go now. I don’t anyone to catch me standing around a G-man.”

“Wait. Where will I find you if I need you to answer some more questions?”

“10th tent down on the left at Occupy Wall Street. It’s right next to the free wireless tent and across from the free Starbucks tent.”

Thursday pulls the coat tighter around him and watches his tipster walk away into the dark, all the while knowing that he had used the man. Yes, it was heartless and cruel, but the CFPB doesn’t cater to weaklings. There are bad bankers out there, it was Thursday’s job to ferret them out and put them out of business, whatever the cost.