The undersigned groups submit these comments on the Consumer Financial Protection Bureau’s (CFPB) four advance notices of proposed rulemaking (ANPR) on whether to propose a rule to change the definition of larger nonbank participants in the auto finance, debt collection, credit reporting and international money transmission markets.
The ANPRs suggest that the number of companies potentially subject to being examined by the CFPB could be reduced dramatically:
- From 63 auto finance companies to as few as 5
- From about 36 consumer reporting agencies to as few as 6
- From 2,500 to 3,000 debt collectors to as few as 11
- From about 28 international money transmitters to as few as 4
We oppose reducing the number of companies that are deemed larger participants in these markets. The CFPB has never supervised all companies that meet the larger participant definitions, but having broader definitions gives the CFPB the flexibility to supervise companies if red flags emerge and to understand compliance issues in companies of different sizes.
Congress intentionally gave the Bureau the tool of supervising nonbank companies in the wake of the financial disasters of the Great Recession. Lack of oversight of nonbanks wreaked havoc on American households and the economy at large. It is paramount that the CFPB maintain a fulsome and rigorous supervision program in order to adequately protect consumers from financial abuse.
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