Last week AFSA sent a letter to the CFPB reiterating enforcement concerns with the nonbank registry. As AFSA previously noted, the rule is overly broad and conflicts with a multitude of consumer protections already in place at both the federal and state levels. Such a backward-looking registry is illogical and could lead to multiple actions by multiple regulators for the same activity that has already been addressed.
The letter highlighted four main issues with the rule:
- This new registry seems currently structured to “name and shame” rather than act as a useful tool to effectively monitor and understand financial markets related to nonbanks and reduce any potential risks to consumers.
- The rule is too broad to properly facilitate an effective risk-based nonbank supervision program.
- The personal attestation requirement will create a disincentive for qualified individuals to take on potential exposure to liability and will make it harder for institutions to fill compliance positions and perform obligations to consumers.
- This effort to create a central registry is unnecessary at best and harmful at worst when it conflicts with the multitude of consumer protections and reporting structures already in place that are accessible to consumers and the CFPB alike.
More CFPB Concerns
Aug 29, 2024
Last week AFSA sent a letter to the CFPB reiterating enforcement concerns with the nonbank registry. As AFSA previously noted, the rule is overly broad and conflicts with a multitude of consumer protections already in place at both the federal… Read the rest
Women’s Equality Day!
Aug 26, 2024
Today, August 26th, AFSA marks the 104th anniversary of Women’s Equality Day and the significant achievement of the 19th Amendment’s ratification. This amendment, passed in 1919 and ratified in August 1920, made an historic… Read the rest
Agency Actions Must Be Limited
Aug 23, 2024
This week, AFSA and other trade organizations filed an amicus brief in support of a vehicle finance company facing an enforcement action from the CFPB, which is attempting to amend settled law that the financial services industry has operated… Read the rest
Back to School Spending and Credit Access
Aug 21, 2024
Back-to-school season is well underway, bringing with it the need for supplies, new clothes, books, and more. According to a National Retail Federation survey, back-to-school outlays for the coming academic year will amount to $39 billion,… Read the rest
Concerns on CFPB’s Medical Debt Rule
Aug 13, 2024
Yesterday, AFSA submitted comments to the CFPB on its proposed rule concerning medical debt. In the letter, AFSA highlighted four specific issues with the proposed rule:
- The CFPB lacks authority for this rulemaking
- At the outset, the CFPB
Industry Expertise | Lien on Me: CHAMP Titles ELT Will Be Your Friend
Aug 12, 2024
“Industry Expertise” is sponsored content produced by AFSA’s Business Partners’ to provide thought leadership and best practices for AFSA member companies. . For more information about this sponsored content opportunity, contact Dan… Read the rest
Loan Forgiveness Denied
Aug 08, 2024
This week, AFSA joined DACO Investments, Westside Credit Corporation, Inc., Motorists Acceptance Corporation, and Challenge Financial Services in filing an Appellant’s Opening Brief in the 5th Circuit. AFSA’s members, like so many … Read the rest
Wither the Soft-Landing?
Aug 05, 2024
Recent stronger-than-expected U.S. economic growth was a top headline in the financial media, and a rare economic soft landing seemed like a sure thing. The major stock market indexes were within shouting distance of all-time highs, and … Read the rest
Featured Business Partner | RSM
Aug 01, 2024
The featured Business Partner for the month of August is RSM.
RSM US LLP is the leading provider of audit, tax and consulting services focused on the middle market, with 12,000 professionals in 84 cities nationwide. Our full range of services
News From Our Members | Alfa presents Intelligent Automation in Alfa Systems 6
Jul 31, 2024
“News From Our Members” is sponsored content produced by AFSA’s Business Partners’ to provide thought leadership and best practices for AFSA member companies. . For more information about this sponsored content opportunity, contact Dan… Read the rest