On June 23, 2011, the Consumer Financial Protection Bureau (“CFPB”) announced it had targeted debt relief services as one of six nonbanking consumer financial market areas that could be classified as “larger participants” and subject to supervision by the CFPB.
The CFPB’s announcement, in the form of a Notice and Request for Comment (the “Notice”), was made in preparation for an eventual rulemaking on a key element of the agency’s nonbank supervision program: the statutory requirement to define who is a “larger participant” in certain consumer financial markets.
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