June 25, 2025
Surviving the CFPB’s Transitional Era
As the regulatory environment continues to shift and technology reshapes the compliance landscape, today’s lending leaders are under increasing pressure to stay agile and forward-thinking.
In this episode, recorded live at CBA Live 2025 in Orlando, host Lynn Sautter Beal sits down with Aaron Rykowski, Chief Compliance Officer at WesBanco, and Mikey Reynolds, Director of Compliance at Zions Bank Corporation. Both serve on the CBA’s CFPB Committee and share how their institutions are responding to growing uncertainty—from changes in CFPB leadership and examiner shortages to the fast-moving rise of AI in compliance.
Join us as we discuss:
- How shifts at the CFPB are shaping compliance strategies
- The challenges of operating with fewer examiners and less regulatory clarity
Where AI and emerging tech fit into modern compliance programs - What lenders need to know about the final 1071 and 1033 rules
- Why collaboration and proactive engagement are essential in today’s environment
WEBVTT
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Hi, Welcome to Leaders and Lending. This is Lynd Souderbil.
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We're joining you today from CBA live in Orlando, and
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I have Aaron Rakowski and Mike Reynolds here joining us
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on the panel. So Aaron, Mike, would you take a
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minute to introduce yourselves and tell our listeners what you do?
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Sure?
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Hi, I'm Eron Kkowsky. I'm the Chief Compliance Officer for
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West Banco, headquart in Wheeling, West Virginia. We're about a
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twenty eight billion asset bank at the current time, with
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offices in nine different states, and I'm responsible for all
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of our regulatory compliance programs.
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You, Mike you Reynolds, I'm Director of Compliance for Science
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Bank Corporation. We're based in Salt Lake City, Utah, and
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we're almost about one hundred billion in assets.
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And Aaron and I realized leading up to this that
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we live probably a couple hours apart in Ohio and
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have met each other for the first time in Orlando, Florida,
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which is always fine. And both of you are on
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this CFPB committee for Sumer Bankers Association.
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So can you kind provide our listeners with kind.
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Of an overview and of how CBA and then its
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members engaged with the CFPV.
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Well, this was a lot clearer answer a couple of
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months ago. Right now the jury's out. We really don't
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know how we're engaging with the CFPV at present, you know,
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given some of the some of the goings on in Washington.
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But you know, ways that we have in the past
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is by having dialogue between the membership of CBA and
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the CFPB, you know, interacting with that agency. And it's
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really unique that we have a committee that is dedicated
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to relationships between the banking industry and a particular regulator.
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And I think that's what makes this committee unique. You
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know this, the regulator has direct supervision authority over banks
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with ten billion assets and larger and has it's a
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unique structure. So having a committee that is able to
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take the concerns of the association's memberships and have that
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dialogue at times directly with the agency, see to provide thoughts, feedbacks, concerns,
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you know, where we think that you know, some of
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their their rulemaking or some of their their activities can
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help benefit consumers and benefit our customers, and you know,
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the membership and communities at largely, I think that that's
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one of the ways we really try to engage, and
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you know, we'd also get feedback from our membership to
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provide input to the Consumer Bankers Association that they use
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when they draft comment letters or when they have discussions
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directly with the regulators as well. So in normal circumstances,
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that's really how we have historically engaged. Right now, Jerry's.
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Out, I would say for us, I mean there's still
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that ongoing or up until maybe two months ago, you know,
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the touch points that we would have with the CPP.
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I'm kind of focusing on what Aaron said to coming
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together in our committee to then you know, discuss kind
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of current trends, things that are going on with exams,
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you know, or hotspots up until about two months ago.
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But still you know, trying to abide by the law
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for what it is right now.
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Sure, and I think you know, we a lot of
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us have talked about that recently, just the uncertainty and
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it's much more straightforward and easy to build a compliance
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organization and a period of clear roles and clear oversight.
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But you know, given the changes in the administration, uh,
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this is probably it's a hard one to forecast. But
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you know, if you had to say what you know,
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what do you think is going to happen, And with
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CFPB regulations in the year ahead, how do you think
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that those may change and ways that impact the CBA members.
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I think a lot of that depends on the time
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frame and confirmation of a new director. So you know,
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obviously there's an arum director and now there's been a
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couple of them since the new administration has taken office.
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But you're really understanding the thought process and priorities of
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the administration and the new director and what that's going
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to look like. So right now it's hard to forecast.
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I know the current nominee for the director has experience
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on the FDIC board, so he knows what it's like
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to be a bank regulator, to be part of an agency,
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to lead an agency, to manage through that. So what
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we're hoping for as members is we kind of get
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back into common sense regulation. You know, enforcement. I believe
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in enforcement, I believe in supervision. But enforce the regulations
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as they are as they're written, examine based on the
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exam manuals as they are and as they're written, and
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have that transparent dialogue with your banks when you're in there.
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You know, part of my background, I'm an next examiner.
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I was an FDIC examiner years ago, and that was
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always the mentality that I took. You know, here's the
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exam manual, here's the rule. How are you complying with this?
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So when we're talking about supervision regulation, you know, I
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would look for and expect the agency to adhere to
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the rules as they're written and follow their exam manuels.
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At least that would be the whole Yeah.
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That's squat point. I mean, we still have to apply
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with rules that are codified you know currently, and all
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of these pending rules that are still under the Congressional
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Review Act, you know, and we have some time still
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to go for some of those. I mean, it's still
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status quo for us. It's nothing normal. And I would
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say even since twenty twenty when COVID hit and we
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had a bunch of regulatory reform because of consumer harm
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and whatnot, you know, I mean, it's just, you know,
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business is usual for us right now.
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So sure, sure, yeah, And we you know, we work
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within a number of banks and credit unions on our platform,
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some banking as a service providers, some traditional banks that
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originate and retain as well as credit unions. And so
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while we're not directly regulated by the prudential regulators, you know,
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we do get state examines examinations, and we support a
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variety of examinations, and we you know, had a partnership
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with the CFPP for a period of time. And I
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think that's the one thing I was talking to some
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other folks earlier, that the banks don't want to do
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consumer harm, right, like you can't harm your customer, you
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still need will do those things even in the absence
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of CFPV may be coming in. So, you know, if
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the CFPP, if some of the trends towards defunding and
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decreasing the size of the CFPB and even some of
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the other regulatory agencies continue or accelerate, even anything that
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you can see on like broader implications for what that
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means for the banking industry as a whole.
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Well, if they see kind of a shrinking of the
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exam workforce, I think that that'll depending on how they
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go about that. I think you could see a lot
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of broad implications. They're both for consumers and consumer protection regulation,
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but also safety and soundness of risk management examinations. You know,
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the way Typically these things happen is they look at
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seasoned examiners at the top of the pay scale and
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offer them, you know, early retirement options, or you look
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at people that are coming up through the ranks and
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maybe going through various schools and training and onboarding that
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have not earned their commission yet to write exams, and
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they maybe let go. They may be probationary employees or
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ones that have not fully gone through the education and
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onboarding process, so the exams have to happen, right, you know.
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From the credential regulatory side, you know there's rules that
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you have to come in every so often to look
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at consumer compliance, to look at community reinvestment, to look
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at fair lended compunts with fair lending laws. And you know,
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a reduced examination workforce is going to leave less resources
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to examine banks, but you also lose that relationship that
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you've built with your regulators. You know, the end goal
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is a safe and sound banking system, a safe and
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sound bank, and nobody wants to do harmon consumers. You
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have been in banking over twenty years and never once
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have I been in a room where somebody said, well,
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let's how much in fees can we get on this
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or how can we really you know, do something other
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than what's in the best interest of our customers. But
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you know, you still have you know, the regulatory side,
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and people need to come in, and a lack of
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experienced examiners that don't have the institutional knowledge, that don't
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have that relationship with management, can't have those sometimes hard
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conversations how did you think this through? Why are you
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doing this this way? It could lead to things that
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don't get caught, or it could lead to questions that
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don't get asked or issues that don't get resolved. So
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you know, when I would look at this, like you know,
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anybody would listen to me anyway, But I would say,
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you know, just kind of proceed with caution when you
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look at right sizing, if that's the right term, an
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examination workforce, to make sure you still have the right
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people looking at the right things on the right frequency.
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And I would say that even though there's a roll
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right now, you know, from that perspective, I mean, we're
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still gearing up for potential state regulation then to kind
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of come in and swing. We've got you know, the
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midterms coming up. I would say in about a year
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and a half and so that may be another pendulum
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swing that we have to then prepare for, or a
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moot house where you know, there's a lot to be
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unexpected I think right now.
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So yeah, and I think that the impact of a
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patchwork of state regulations that may be very strong would
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be very difficult to deal with. You know, even for
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a fintech like ours that lends nationally or works with
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banks to lend nationally, those state regulations can be very
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difficult for us to manage our business and understand volume
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and and ensure that we're we're applying them, like the
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Colorado UH law, if we had to put that into effects,
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you know, and spending time and money and and certainly
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a time and money expends on banks for for especially
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with uncertainty and less clear I really liked it you said, though, Aaron,
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about less experienced examiners and kind of the team where
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you know, they really maybe knew the bank partnership and
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and had insight there, particularly as it relates to say,
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you know, use of AI partnerships with FinTechs UH or
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or new technologies.
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You know, what would.
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You you know, one with some of the changes in
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the regulatory bodies right now, like what do you think
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the risks are there in their ability to oversee those?
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And I guess I would say too, like, you know,
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how how can the cb I members think about working
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with them to maybe help educate them on the new
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technologies or partnerships that they have.
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It's a very broad question. So I think here AI
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is becoming more prevalent. General of AI is becoming more prevalent,
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and I think that banks and through that through just
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using it directly, developing it directly, or partnering with FinTechs
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offering it directly. You know, they're looking to find ways
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to go to market and work with their customers in
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the most efficient way possible, and this is kind of
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a way to do that. Really, looking at the risks
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of AI, it's to me, you know, starting with your
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third party management or risk management program and being sure
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you understand what the what the service is, what the
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AI can do, what the variables are, because again, the
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the compliance risk is always there and it's still there,
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ends Mikey mentioned earlier, the codified rules and regulations are
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still there. We still have an you know, upstarting the
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lending space and looking at AI and Algareth algorithms used
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in lending for automated decision and approval. You still have
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to ensure that those models that you're using, the AI
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you're using is operating fairly. You know those rules and
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those laws. Equal credit opportunity does not go away. You
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know you're still going to be examined for it. You
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still have your prudential regulators that can look at fair
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housing if you're in the mortgage space and using some
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AI to help with your decision making. So you know,
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the basic blocking and tackling of your compliance program does
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not change regardless of you know, the political environment or
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the regulatory environment. And just be honest, because things ebb
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and flow. You know, we've seen a lot of ebb
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and flow over the last ten years as far as
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which administration is currently sitting in the White House or
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which administration or which party is currently controlling Congress. You
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see swings back and forth. So the rules are still
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the same. And making sure that you're doing your own
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due diligence and understanding how these things are working. It's
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central to what we're trying to do from a compliance
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perspective in how we govern the use of AI in
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our banks and in our shops.
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That's a great point. I mean it's specifically talking about
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AI and you know, focusing on operational effectiveness kind of
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in this lull from a regulatory perspective that we're in.
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I mean, you still think that, you know, these fraudsters
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out there are using fourth generation bots as we move
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into fifth generation technology and things like that where they're
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starting to dart smell or outsmart the banks. As Aaron mentioned,
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