Delivering the keynote address last week at the Consumer Federation of America’s 2022 Consumer Assembly, CFPB Deputy Director Zixta Martinez indicated that the CFPB “is taking a close look” at “‘rent-a-bank’ schemes.”

Deputy Director Martinez commented that “[s]ome lenders attempt to use [relationships with banks] to evade state interest rate caps and licensing laws by

The CFPB has announced that it plans to invoke its “dormant authority” to supervise nonbanks engaged in conduct that poses risk to consumers.  In conjunction with the announcement, the CFPB issued a procedural rule concerning the confidentiality of proceedings in which the CFPB invokes such authority.  These moves by the CFPB are notable for two

The CFPB has adopted its long-awaited final rule setting forth the procedures it will use to supervise nonbanks engaged in conduct that poses risks to consumers.  The final rule will be effective 30 days after its publication in the Federal Register. 

We expect the CFPB to quickly begin asserting its risk-based supervisory authority.  In fact,

The official launch of the CFPB’s nonbank supervision program was the subject of a blog post by Peggy Twohig, the CFPB’s Associate Director for Nonbank Supervision, and Steve Antonakes, Associate Director for Large Bank Supervision. While much of the post rehashes comments made by Richard Cordray following his recess appointment as Director, a few items