Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
As previously reported, in June 2024 the CFPB issued a final rule creating a Nonbank Enforcement Order Registry. The rule is effective on September 16, 2024, with registrations available beginning on October 16, 2024 pursuant...more
Who's Covered: Registrations and Written Statements - Generally, a covered nonbank with a covered order in effect on or after September 16, 2024, must register and submit information to the CFPB about the entity and the...more
In a move that's sure to make nonbank financial institutions even more uncomfortable, the Consumer Financial Protection Bureau (CFPB) has decided to shine a brighter light on those that have been alleged to violate consumer...more
Constitutionality concerns cleared, the Consumer Financial Protection Bureau (CFPB) on June 3 issued its final rule creating a registry identifying covered nonbanks subject to government agency enforcement orders. The rule's...more
On June 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule requiring covered nonbanks to register enforcement orders, and it is a doozy. Not only will covered nonbanks be required to register...more
Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
On June 13, Nevada’s governor signed into law Senate Bill 290 creating the nation’s first statutory framework for earned wage access (EWA) providers operating in the state. The law appoints the state’s Commissioner of...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
The Illinois Department of Financial and Professional Regulation adopted rules to repeal and amend parts of the Residential Mortgage License Act, including, but not limited to...more
D.C. License Applications. The District of Columbia Department of Insurance, Securities and Banking recently started to accept applications and transition fillings for a Student Loan Servicer License on the National Mortgage...more
In a Request for Information (RFI) posted on the Federal Business Opportunity website last month, the Consumer Financial Protection Bureau (CFPB) solicited information from vendors so it can "better understand current,...more
oin Pepper Hamilton LLP, the Conference of State Bank Supervisors (CSBS) and RECOVCO Mortgage for an engaging discussion about important recent trends involving state supervision as states shift an ever greater amount of...more
In This Presentation: - Events That Changed Our World; And Yours Too! - Current Issues in Licensing - State Coordination With CFPB - The Path to Coordination - Responsibilities of the SCC ...more
The CFPB has issued guidance that provides states may use the Uniform State Test (UST) developed by the Nationwide Mortgage Licensing System and Registry (NMLSR) to satisfy the testing requirement of the Secure and Fair...more