The Consumer Financial Protection Bureau (CFPB) has broad powers, the ability to extend its own reach and extensive power to impose financial penalties, according to Christopher Willis, partner at the law firm of Ballard Spahr and the firm’s leader of Consumer Financial Services Litigation.

The reach and scope of the CFPB is often viewed as more limited than it actually is in practice, he told attendees at Furniture/Today’s Finance Symposium.

The CFPB has examination authority similar to that of federal bank regulators. However, the bureau’s more extensive reach comes from its “enforcement jurisdiction over any person or entity engaged in providing a ‘consumer financial product or service,’ which includes extending credit, servicing loans and collecting consumer debt. This provision of CFPB’s mandate gives it the ability to determine its own scope of authority and has recently led the bureau to take action in the car leasing arena,” said Willis, “a marketplace that could have significant ramifications for the furniture industry and lease-to-own finance companies.”

The best way to avoid running afoul of the CFPB is to ensure compliance at the outset. One area that frequently is reviewed by the bureau is Unfair, Deceptive or Abusive practices, so that should be an area of focus. Reviewing all aspects of a company’s credit processes—from advertising origination, underwriting and servicing, to collections and debt sales—also is important.

Proper handling of customer complaints also is critical.

A good rule of thumb, Willis noted is, “Would this be ok if this happened to Mom.”