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Consumer Financial Protection Bureau (CFPB) Non-Bank Lenders Financial Institutions

Husch Blackwell LLP

CFPB Floats Rescission of NBR Rule

Husch Blackwell LLP on

The Consumer Financial Protection Bureau (CFPB) continues to redefine its priorities, and among the many policies targeted for change, the “Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders”...more

Ballard Spahr LLP

CFPB proposes to rescind rule requiring nonbanks to register certain agency enforcement and court orders

Ballard Spahr LLP on

The CFPB is proposing to rescind its rule that requires certain nonbank entities to register covered agency enforcement and court orders....more

Troutman Pepper Locke

The Reversals Continue: CFPB Proposes Rescission of Supervisory Designation Amendments

Troutman Pepper Locke on

On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind its nonbank registry rule

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule requiring nonbanks to report the existence of an order and file annual compliance reports where such nonbanks were subject to certain final...more

Ballard Spahr LLP

CFPB rescinds enforcement, supervisory priority documents, outlines new priorities for 2025

Ballard Spahr LLP on

The CFPB is rescinding its existing enforcement and supervision priority documents, according to a memo sent to bureau staff by CFPB Chief Legal Officer Mark Paoletta....more

Ballard Spahr LLP

CFPB to hold two virtual sessions to answer questions about Nonbank Registry Rule

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The CFPB will hold two virtual sessions later this month to answer questions about its Nonbank Enforcement Action Registry rule. The rule, issued in June 2024, will require certain nonbank entities to register certain covered...more

Troutman Pepper Locke

The CFPB's Nonbank Registry Rule: Challenges and Implications — The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Jesse Silverman and Matt Morris to explore the complexities of the CFPB's nonbank registry rule. This regulation, introduced in 2024, has...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: The CFPB’s Registry of Nonbanks and Circular that Certain Contract Terms Violate Law

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The CFPB recently issued yet another final rule the agency says will help deter violations of consumer protection laws. This rule requires certain nonbank entities to register with the CFPB upon becoming subject to any order...more

Hinshaw & Culbertson - Consumer Crossroads

CFPB Publishes Filing Instructions for its New Nonbank Registry for Repeat Offenders

On August 23, the Consumer Financial Protection Bureau (CFPB) issued its Filing Instructions Guide ("Guide") for Nonbank Registration pursuant to its Registry of Nonbank Covered Persons Subject to Certain Agency and Court...more

Alston & Bird

CFPB Expands its Reach with Final Rule Establishing Nonbank Registry of Public Settlements, Consent Orders and Enforcement Actions

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What Happened? On June 3, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule (the Final Rule), a 486-page rule...more

Brownstein Hyatt Farber Schreck

CFPB Publishes Final Nonbank Registry Rule

On June 3, the Consumer Financial Protection Bureau (CFPB) published a final rule to create a registry of nonbank companies that have entered into consent agreements or who have otherwise been found by the bureau to be in...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 29: The CFPB’s Expanding Supervisory Authority of Fintechs and Other Non-Banks

In our latest look at the CFPB’s expanding supervisory authority of fintechs and other non-bank financial service providers, RegFi cohosts Jerry Buckley and Sasha Leonhardt welcome fellow Orrick partner — and former deputy...more

Ballard Spahr LLP

House members urge CFPB to define “risk to consumers” in procedural rule on risk-based supervisory authority

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A bi-partisan group of House members has sent a letter to CFPB Director Chopra to express concern about the CFPB’s rule setting forth its procedures for establishing supervisory authority over nonbanks engaged in conduct that...more

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Fintech

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2023 applicable to fintech. The Consumer Financial Protection Bureau (CFPB) and its director, Rohit Chopra, continued the agency's focus on the everyday consumer...more

Alston & Bird

FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations

Alston & Bird on

A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 31, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Ballard Spahr LLP

CFPB enters into consent order with remittance transfer provider

Ballard Spahr LLP on

The Consumer Financial Protection Bureau announced that it has entered into a Consent Order with Chime Inc., a nonbank fintech company, to settle alleged violations of the Electronic Fund Transfer Act (EFTA), Subpart B of...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

McGlinchey Stafford

CFPB Loses Novel Redlining Case Against Non-Bank Mortgage Lender

McGlinchey Stafford on

On February 3, 2023, an Illinois federal judge dismissed with prejudice Bureau of Consumer Financial Protection v. Townstone Financial Inc. et al., the Consumer Financial Protection Bureau’s redlining case against a non-bank...more

Alston & Bird

Structured Finance Spectrum – February 2023

Alston & Bird on

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features a new year for a new UCC Article 12, a farewell to LIBOR, and an appraisal...more

McGlinchey Stafford

CFPB Proposes Databases Highlighting UDAAP Judgments, Form Contract Provisions

McGlinchey Stafford on

Continuing its trend of aggressive oversight over financial institutions, the CFPB has recently announced proposals to create two publicly accessible databases that, it says, will highlight alleged bad actors, identify...more

Cadwalader, Wickersham & Taft LLP

CFPB Issues Proposed Rule on Form Contracts

The Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule last week addressing the “Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Registry of Terms and Conditions for Nonbanks

On January 11, the CFPB proposed a rule requiring nonbanks subject to its supervisory authority, with limited exceptions, to annually register with the CFPB regarding their use of certain terms and conditions in form...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: Issue 12, December 2022

US Senators Ask SoFi About Its Banking Law Compliance = “Four U.S. senators have signed a letter to SoFi Technologies CEO Anthony Noto expressing concerns about the online personal finance company and online bank’s digital...more

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