Larger Participants

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On May 23, 2012, the CFPB published an advanced notice of proposed rulemaking (ANPR) that proposes to extend Regulation E protections to GPR cards. The CFPB’s release of this ANPR coincided with the CFPB’s scheduled hearing in Durham, North Carolina on the same subject. We previously issued an e-alert summarizing the ANPR and wanted to provide some further thoughts and commentary on the ANPR.… Continue Reading

The CFPB has announced that it will be holding a field hearing on prepaid cards in Durham, North Carolina on Wednesday, May 23, 2012. Director Cordray will be delivering remarks and testimony is expected from consumer and civil rights groups, industry representatives, and members of the public. The event is open to the public but an RSVP is required, which can be sent to cfpb.events@cfpb.gov… Continue Reading

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. … Continue Reading

This morning, the CFPB released a proposed rule to define “larger participants” subject to its supervision and enforcement authority.  We will write more about this proposed rule after we get the chance to review it, but from an initial review of the press release, there are several interesting aspects to the proposed rule:

  • Initially, the CFPB is seeking to cover only “large” consumer reporting agencies and debt collectors, with revenue thresholds of $7 million and $10 million, respectively, to define the covered entities.
… Continue Reading

The National Consumer Law Center seems to be urging the CFPB to adopt a “Hotel California” approach to its supervision of larger participants. Referred to as the “Hotel California” provision, the Dodd-Frank Act provides that large bank holding companies that accepted TARP money remain subject to Fed supervision even if they give up their BHC status.… Continue Reading