CFPB Proposed Rule Change: Repeat Offender Registry

Partners David Monteiro and Andrew Ray and of counsel Nicholas Gess discussed a new proposed rule change from the Consumer Financial Protection Bureau (CFPB) with members of the Financial Technology Association that would establish a registry where certain nonbank financial institutions must deposit copies of certain federal, state, and local orders. Their discussion included key takeaways from the proposed rule change—which would require all non-bank institutions to report resolutions to the CFPB and require large non-bank institutions to certify compliance with all orders—and examined some of the potential risks and pitfalls associated with these new changes.