CFPB Expands Supervisory Authority Over Nonbanks – What You Need to Know
Event summary
On February 23, 2024, the Consumer Financial Protection Bureau (CFPB) made public an order under never-before-used authority to bring under its supervision, on the basis that it poses risks to consumers, a nonbank financial institution – an institution that, absent such a finding, it could not examine. Under the Dodd-Frank Act, Congress granted the CFPB automatic authority to examine only certain nonbank providers of financial products and services – institutions engaged in mortgage lending and servicing, private student lending, and payday lending. CFPB rules also permit the agency to examine larger nonbank participants involved in consumer reporting, debt collection, student loan servicing, international money transfers and auto lending.
The order released on February 23 details the path for the CFPB to supervise other institutions it deems “risky” – which is likely to include smaller nonbank financial services providers and fintechs offering novel products and services.
This webinar for clients and industry members discussed the order’s potential impact on nonbank providers that have lived outside the CFPB’s supervisory jurisdiction, the “consumer risk” supervisory designation process and the centrality of consumer complaint management to this process.
For more information, please email Rebecca Lanz.
Related contacts
This content is provided for general informational purposes only, and your access or use of the content does not create an attorney-client relationship between you or your organization and Cooley LLP, Cooley (UK) LLP, or any other affiliated practice or entity (collectively referred to as “Cooley”). By accessing this content, you agree that the information provided does not constitute legal or other professional advice. This content is not a substitute for obtaining legal advice from a qualified attorney licensed in your jurisdiction and you should not act or refrain from acting based on this content. This content may be changed without notice. It is not guaranteed to be complete, correct or up to date, and it may not reflect the most current legal developments. Prior results do not guarantee a similar outcome. Do not send any confidential information to Cooley, as we do not have any duty to keep any information you provide to us confidential. This content may be considered Attorney Advertising and is subject to our legal notices.