The Bureau of Consumer Financial Protection (the “Bureau” or the “CFPB”) may have increased the incidence of triskaidekaphobia among banks and consumer financial service companies when it released Bulletin, 2012-03i (the “Bulletin”) on Friday, April 13, 2012. In the Bulletin the Bureau announced its intent to exercise supervisory and enforcement authority over how banks and non-bank consumer financial service companies control their third-party vendors (e.g., service providers such as subservicers, foreclosure trustees and law firms, and force place insurers, to name a few).

In the Bulletin, the CFPB announces its “expectations” of the financial institutions over which the Bureau has jurisdiction (which include the nation’s largest banks and most non bank providers of consumer financial products and services). The CFPB is effectively mandating those institutions to...