Changes to Risk-Based Supervision Rules
The CFPB has announced changes to its procedures for imposing risk-based supervision on non-bank consumer finance companies. Earlier this year, the CFPB asked for comments on making changes to these procedures. AFSA commented, agreeing with the CFPB that its proposed changes would be helpful to reduce coercion of consumer finance companies and reduce unfairness.
The new changes track AFSA’s comments, restoring confidentiality to the supervisory designation process and making it more deliberative. Originally, the process involved CFPB staff making recommendations to the Director, but power was concentrated with the Director in later versions. We are pleased to see that the CFPB has gone back to the initial approach. This final rule will be effective October 27.
September 25th, 2025
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