Venable of counsel Jonathan Pompan was featured in the September 2012 edition of Career Education Review in which he offered detailed recommendations to private sector colleges and universities in anticipation of future Consumer Financial Protection Bureau (CFPB) regulations and investigations.
Pompan urged schools to prioritize the implementation of a "robust compliance program that takes into account the rules and regulations that CFPB has enforcement over, as well as internal audits and controls to identify any gaps in compliance." He also cautioned all private schools to prepare for potential CFPB investigations, saying "The bureau is causing a lot of uncertainty. These investigations can come with significant costs and distractions for a school, especially for those that are not active or consider themselves inactive in the private student loan space. Many schools traditionally haven't considered themselves to be significant players in the private student loan space, but nonetheless, they could get caught up in these investigations."
In highlighting the CFPB's assertive regulatory approach, Pompan observed that "Until any of its investigative work concludes and if it were to become public, it's difficult to know precisely where the bureau is looking to draw the line. That being said, they clearly aren't waiting to draw the line first and investigate second."