After suggesting six possible markets for consumer financial products and services in which it might supervise “larger participants,” the CFPB has decided that, at least for the time being, it will only supervise “larger participants” in two of those markets, namely debt collection and consumer credit reporting. 

In issuing its proposed “larger participants” rule, the CFPB gave no explanation for its decision to include just the two markets.  Director Cordray has been quoted as commenting that consumers don’t get to choose their debt collector or whether consumer reporting agencies keep track of their credit history.  Perhaps it was that perceived lack of choice that led the CFPB to focus initially only on debt collection and consumer credit reporting.  

Because of the proposal’s significance, we have prepared a legal alert that contains a detailed discussion of the proposal’s highlights.