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Financial Services Law Insights and Observations

CFPB Considers Registration Rule for Nonbank Financial Institutions

CFPB Vendors Data Collection / Aggregation

Consumer Finance

The CFPB recently issued a Request for Information (RFI) seeking vendor feedback on the agency’s consideration of establishing a web-based system that would require nonbank financial institutions to register with the CFPB. The RFI outlines the potential registration system’s capabilities and services, noting that nonbank financial institutions would use it to “apply for, amend, update, or renew a registration online using a single set of uniform applications.” In addition to other data gathering components, the potential registration system may be used for the collection of financial, operational, and organizational structure data. Responses from technology system vendors were due on July 29, 2016, with a disclaimer that the RFI was not “to be construed as a commitment that the CFPB will propose a rulemaking on the registration of nonbank financial institutions or that the CFPB will propose any specific system requirements.”