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Proposed Rules Consumer Financial Protection Bureau (CFPB) Non-Bank Lenders

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

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 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

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

Shipkevich PLLC

Credit Card Rewards Programs Oversight – The Next Notch in the CFPB’s Payments Space Regulatory Belt

Shipkevich PLLC on

In another move highlighting the Consumer Financial Protection Bureau's (the “Bureau” or “CFPB”) continued focus on the payments space, the CFPB has issued a new report finding consumers are encountering numerous problems...more

Troutman Pepper Locke

The Future of Digital Consumer Payment Applications: CFPB's Proposed Larger Participant Rule – The Consumer Finance Podcast and...

Troutman Pepper Locke on

In this special joint episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, James Kim, and Chris Willis discuss the Consumer Financial Protection Bureau's (CFPB) proposed larger participant...more

Paul Hastings LLP

CFPB Takes Steps to Supervise Digital Payments Apps

Paul Hastings LLP on

On November 7, 2023, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would allow it to exercise its supervisory authority over larger nonbanks offering digital consumer payment applications, such...more

Husch Blackwell LLP

CFPB Signals New Proposed Rule on Nonbank Supervision in the Consumer Payments Market

Husch Blackwell LLP on

The Consumer Financial Protection Bureau (CFPB) recently released its Spring 2023 rulemaking agenda, signaling an expansion of its supervisory authority over the payments market. Of particular interest is the introduction of...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

Husch Blackwell LLP

Aggressive CFPB Rulemaking Attempts to Create Registry of Nonbank Contract Provisions

Husch Blackwell LLP on

On February 1, 2023, the Consumer Financial Protection Bureau (CFPB) published a proposed rule that, if implemented, would require most nonbanks subject to the CFPB’s supervisory authority, with limited exceptions, to submit...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

Shipkevich PLLC

CFPB Proposed New Rule to Establish Public Registry of “Take It Or Leave It” Contract Terms and Conditions

Shipkevich PLLC on

On January 11, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a new rule to apparently shed light on the dark corners of the financial industry. The proposed rule would create a public registry of the fine...more

Husch Blackwell LLP

CFPB Attempts to Expand Scope of Nonbank Surveillance

Husch Blackwell LLP on

Without its typical fanfare, the CFPB has revealed a plan to propose a rule titled “Nonbank Registration – Terms and Conditions” in its “Agency Rule List - Fall 2022.” The description of the proposed rule is scant, a mere...more

Buchalter

CFPB Proposes That Non-Bank Consumer Finance Companies Must (1) Register all Federal, State and Local Regulator Enforcement Orders...

Buchalter on

Registration of Regulator Orders and Court Judgments - On December 12, 2022, the CFPB issued a proposed rule regarding non-bank consumer finance firms registration of all settlements and enforcement orders. The proposed...more

Shipkevich PLLC

CFPB Issues Proposed Rule Imposing Reporting Requirements on Certain Non-Bank Entities: Possible Implications for Money...

Shipkevich PLLC on

On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule pursuant to its authority under the Consumer Financial Protection Act of 2010 (CFPA). This rule would require certain non-bank...more

Sheppard Mullin Richter & Hampton LLP

FinTechs in Crosshairs as CFPB Invokes Dormant Authority to Examine Nonbanks

On April 25, the CFPB announced that it is using its “dormant authority” in order to conduct examinations of nonbanks posing risks to consumers.  The Bureau has direct supervisory authority over banks and credit unions,...more

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