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ARTICLE · 04 AUGUST 2011

CFPB Request For Comment: Identifying Non-Depository Companies For Direct Examination And Supervision

Venable LLP
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On June 29, 2011, the CFPB (through the auspices of the Treasury) published in the Federal Register one of its most significant notices to date.

United StatesConsumer Protection
Joseph Lynyak, III
Joseph Lynyak, III
Maura Marcheski
Maura Marcheski

Summary

On June 29, 2011, the CFPB (through the auspices of the Treasury) published in the Federal Register one of its most significant notices to date. (76 Fed. Reg. 38059) Specifically, the CFPB has asked for public comment to identify "larger" non-depository providers of consumer financial products and services that will be supervised and examined directly by the CFPB. Among other things, the identification process will also include requiring specified entities to register with the CFPB, to provide regular reports of their activities, and to become subject to direct enforcement for violation of federal consumer laws by the CFPB.

Discussion

The Dodd-Frank Act provides the CFPB with direct supervision over all depository institutions worth over $10 billion, plus the following non-depository entities regardless of size:

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