News & Analysis as of

Non-Bank Lenders Consumer Financial Protection Bureau (CFPB)

Cadwalader, Wickersham & Taft LLP

Summer’s Over and the Regulations Keep Coming, September 2025 - End of Summer Regulatory Round-Up

As summer comes to an end, here is a round-up of regulatory activities in financial services: Consumer Financial Protection Bureau Sues Synapse. The fintech filed for bankruptcy in April 2024 has been sued by the CFPB on...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes rule clarifying supervisory designation standard for nonbanks

On August 26, the CFPB issued a proposed rule to clarify the legal standard when determining whether to designate a nonbank covered person for Bureau supervision under Section 1024(a)(1)(C) of the CFPA. The proposal would...more

Ballard Spahr LLP

CFPB files complaint against Synapse Financial Technologies

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The CFPB has filed a complaint against Synapse Financial Technologies Inc, alleging that the company engaged in unfair acts and practices in violation of the Section 1036(a)(1)(B) of the CFPA by failing to maintain sufficient...more

Troutman Pepper Locke

CFPB Proposes Stricter Standards Limiting Supervision of Nonbanks

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The Consumer Financial Protection Bureau (CFPB or Bureau) is taking a significant step to modify its supervisory approach to nonbanks by publishing a proposed rule advancing a more stringent definition of “risks to consumers”...more

Morgan Lewis

CFPB Invites Comment on Larger Participant Thresholds

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The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

Troutman Pepper Locke

CFPB Proposes Rules Re-Defining Larger Participants in Multiple Markets

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On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the...more

Ballard Spahr LLP

CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds

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On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more

Holland & Knight LLP

CFPB Seeks Comments on Increased Larger Market Participant Thresholds in 4 Key Markets

Holland & Knight LLP on

The CFPB published four advanced notices for proposed rulemaking in the Federal Register on Aug. 8, 2025. Each notice seeks comment from experts within the automobile financing, international money transfer, consumer...more

Brownstein Hyatt Farber Schreck

CFPB Proposes Changes for Supervision of CRAs, Debt Collection, Money Markets and Auto Finance Markets

As part of ongoing efforts from the Trump administration to streamline regulatory efforts, the Consumer Financial Protection Bureau (CFPB) is proposing changes to Larger Market Participant thresholds, many of which currently...more

Troutman Pepper Locke

Mass. AG Emerges as Key Player in Consumer Protection

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Massachusetts Attorney General Andrea Campbell has emerged as a significant figure in the landscape of consumer protection and corporate accountability. Her actions and initiatives have positioned her as a thought leader...more

Troutman Pepper Locke

NYC Comptroller Requested Stronger Protections for New Yorkers Amidst Attenuated CFPB Authority

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New York City Comptroller Brad Lander released a report titled “Standing Up for New York Consumers – How New York State and New York City can Strengthen Consumer Financial Protection in the Trump Era,” which called for the...more

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

Sheppard Mullin Richter & Hampton LLP

CFPB and DOJ Terminate Another Redlining Consent Order

On June 2, the U.S. District Court for the Eastern District of Pennsylvania terminated a 2022 consent order and dismissed with prejudice the CFPB and DOJ’s redlining lawsuit against a nonbank mortgage lender. The motion to...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes to Rescind Risk-Based Supervision Rulemaking

On May 14, the CFPB issued a proposed rule to rescind recent amendments to its nonbank supervisory program. The amendments were designed to expand and formalize the Bureau’s process for subjecting nonbank covered persons to...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

Ballard Spahr LLP

Trump signs resolution voiding CFPB large nonbank supervision rule

Ballard Spahr LLP on

President Trump has signed a resolution nullifying the rule implementing the CFPB’s power to supervise large nonbank financial services providers of general-use digital consumer payment applications....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 amendments to nonbank supervision

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule on the Procedures for Supervisory Designation Proceedings. These amendments were each codified in 12 C.F.R. 1091. As previously covered by...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

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

Troutman Pepper Locke on

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

Orrick, Herrington & Sutcliffe LLP

CFPB announces it will not enforce compliance with nonbank registry rule

On April 11, the CFPB announced it would not “prioritize enforcement or supervision actions” regarding entities who do not meet the registration deadlines under the nonbank registry rule. As previously covered by InfoBytes,...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces It Will Not Prioritize Oversight of Repeat Offender Registry

On April 11, the CFPB announced that it will not prioritize enforcement or supervision against nonbank financial companies that miss registration deadlines under its Repeat Offender Registry. The Bureau also stated that it is...more

Ballard Spahr LLP

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

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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, DoJ take action in redlining cases

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The CFPB has taken action against the Draper & Kramer Mortgage Corp. (DKMC) based on allegations of discriminatory lending activities that, according to the CFPB, discouraged homebuyers from applying to the company for home...more

Sheppard Mullin Richter & Hampton LLP

CFPB Sues Mortgage Lender for Predatory Lending Practices in Manufacture Homes Loans

On January 6, 2025, the CFPB filed a lawsuit against a non-bank manufactured home financing company for violations of the Truth in Lending Act and Regulation Z. The lawsuit alleges that the mortgage lender engaged in...more

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