RegFi Episode 24: What will Supervisory Exams Look Like for Tech Companies under CFPB’s Proposed “Larger Participant” Rule?

The CFPB’s Proposed Larger Participant Rule for Payments Providers, if adopted, will subject large tech companies providing payments services and mobile wallets to bank-like supervisory examinations of their payments activities. Tech companies offering consumer finance services are already subject to CFPB enforcement, but the proposed rule would result in ongoing regulatory supervision by the Bureau. RegFi co-hosts Jerry Buckley, Sasha Leonhardt, Sherry Safchuk and Caroline Stapleton expand on their coverage from earlier this year, delving deeper into what newly covered institutions might expect from the examination process. The conversation includes an outline of the typical examination lifecycle, a discussion of likely CFPB supervisory priorities, and preparatory steps companies can take now to manage the exam process and reduce potential regulatory risks.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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