In an October bulletin, the Consumer Financial Protection Bureau (CFPB) published an appeals process that grants banks and other financial institutions the right to challenge compliance ratings and other supervisory findings issued by the bureau. They may petition for review of an unsatisfactory compliance rating, in writing, within 30 days of issuance.

Christopher J. Willis, a litigation partner in Ballard Spahr's Consumer Financial Services and Mortgage Banking Groups, observed that the CFPB bulletin strongly emphasizes fair lending issues while ignoring other aspects of supervision.

"Fair lending seems to pervade everything the CFPB talks about, and this bulletin is no exception," Mr. Willis said. "Does it suggest they are anticipating appeals from fair lending-related supervisory actions?"

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