The Consumer Financial Protection Bureau (“CFPB”) continues to move forward with implementation of its nonbank supervision program by releasing the procedures it will use in examining credit bureaus and other consumer reporting companies. According to the Bureau, “these procedures are a field guide for CFPB examiners looking to check that these companies are following the law.” The CFPB’s authority to supervise consumer reporting companies takes effect September 30, 2012.
The Dodd-Frank Act gave the CFPB authority to supervise “larger participants” in the consumer financial markets as defined by rule. In July 2012, the CFPB identified a market for consumer reporting and defined larger participants to include companies in that market that have more than $7 million in annual receipts. According to the CFPB, its supervisory authority will cover an estimated 30 companies that account for about 94 percent of the market’s annual receipts.
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