The Consumer Financial Protection Bureau (CFPB) has released detailed compliance guides for its new rule that establishes a registry of nonbank entities subject to enforcement actions. This significant regulation, which takes effect on September 16, 2024, mandates that nonbank entities, including debt collectors, register with the CFPB if they have been subject to enforcement actions by local, state, or federal courts or agencies.
However, while the rule itself goes into effect in September, the online registry will not be operational until October 16, 2024. Additionally, regulated entities are expected to comply with the rule on a staggered schedule, depending on their classification.
Key Dates and Requirements
The final rule outlines specific registration deadlines for different types of nonbank entities:
Larger Participant CFPB Supervised Covered Nonbanks
– Registration Submission Period: October 16, 2024, through January 14, 2025
– Registration Deadline: January 14, 2025
Other CFPB-Supervised Covered Nonbanks
– Registration Submission Period: January 14, 2025, through April 14, 2025
– Registration Deadline: April 14, 2025
All Other Covered Nonbanks
– Registration Submission Period: April 14, 2025, through July 14, 2025
– Registration Deadline: July 14, 2025
Compliance Guidance
The CFPB has provided several compliance guides to assist entities in navigating this new requirement. These include:
- Filing Instructions Guide
- Company Registration Sample Form
- Instructions for Viewing State Regulatory Actions in NMLS
These guides, along with additional resources, are available on the CFPB’s website. The bureau will also publish company information on a public online registry, with certain details made accessible on its public-facing site. Entities with questions regarding nonbank registration or related compliance issues can reach out to the CFPB via email at NBRHelp@cfpb.gov.
The implementation of this registry is expected to have a significant impact on the accounts receivable management industry, as it brings additional oversight and transparency to nonbank entities involved in financial services.
Author: Jennifer Evancic
Jennifer.Evancic@ResourceManagement.com
Jennifer Evancic is a third-party auditor valued by creditors and large organizations for her knowledge in call monitoring within the collections industry. With meticulous attention to detail and a firm grasp of regulatory requirements, she ensures compliance with clients’ criteria and state and federal regulations.
Jennifer audits collections calls, ensuring they meet client-specific criteria and comply with regulations, providing valuable insights and maintaining industry standards.
Beyond her auditing responsibilities, Jennifer takes the lead in organizing and facilitating monthly call calibrations. These sessions serve as a collaborative forum where clients and their vendors come together to discuss call monitoring results and address any findings or areas for improvement. Jennifer’s guidance fosters open communication and ensures alignment between clients and vendors, driving continuous improvement in collections practices.
Jennifer stays up-to-date with compliance and industry best practices by participating regularly in peer meetings, regulatory updates and industry webinars. This keeps her informed about emerging issues and ensures she remains a knowledgeable leader in collections compliance.
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