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ARTICLE · 13 MARCH 2024

CFPB Issues Order Establishing Supervisory Authority Over Nonbanks

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On February 23, 2024, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") published an order establishing supervisory authority over a small-loan...

United StatesConsumer Protection
Christa Bieker
Christa Bieker
Tori K. Shinohara
Tori K. Shinohara
Joy Tsai
Joy Tsai
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On February 23, 2024, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") published an order establishing supervisory authority over a small-loan consumer finance company, using a Dodd-Frank Act provision that allows the Bureau to supervise certain nonbanks that it has reasonable cause to determine pose risks to consumers (the "Order"). The Order represents the CFPB's first publicized use of this authority in a contested case.

The Order provides insight into how the Bureau views its authority to designate certain nonbank entities for supervision. In this Legal Update, we summarize relevant aspects of the Bureau's supervisory authority, and highlight key takeaways from the Order.

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