On February 18, Steven Antonakes, Deputy Director of the CFPB, delivered remarks before the Exchequer Club of Washington, D.C. regarding the CFPB’s risk-focused supervision program. In his remarks, Antonakes identified two key differences that distinguish the CFPB from other regulatory agencies: (i) there is a “focus on risks to consumers rather than risks to institutions;” and (ii) examinations are conducted by product line rather than an “institution-centric approach.” Antonakes further stated that the agency uses field and market intelligence, which includes both qualitative and quantitative factors for each product line, such as the strength of compliance management systems, findings from CFPB’s prior examinations, the existence of other regulatory actions, the consumer complaints received, and metrics gathered from public reports, to adequately assess risks to consumers from an institution’s activity in any given market. After the review period, an institution will receive a “roll-up examination report” or a “supervisory plan,” depending on size, that will summarize the findings of the review. If corrective action is warranted, a review committee will assess violation-focused factors, institution-focused factors, and policy-focused factors to determine whether the examination should be resolved through a supervisory action or a public enforcement action.