CFPB Issues Filing Instructions for Nonbank Registry

The CFPB issued comprehensive filing instructions for nonbank entities to register with the agency's new "Nonbank Registry" ("NBR"). The NBR, which is expected to go live on October 16, 2024, is intended to "detect and deter corporate offenders that have broken consumer laws and are subject to federal, state, or local government or court orders." (See related coverage.)

In the "Nonbank Registration Filing Instructions Guide," the CFPB described the information that must be provided to the registry and specific filing instructions through the NBR Portal. The CFPB said "these resources may be useful for employees in a variety of roles, including compliance staff or vendors that help develop compliance systems." The CFPB said the NBR will provide practical information for:

• Identifying affected institutions, products, departments and staff. The CFPB said entities will "want to determine those affected within their entity" so as to provide the "appropriate staffing and training."
• Identifying changes to business processes, policies and systems. The CFPB said entities must put procedures in place to comply with the registration requirements.
• Identifying impacts to affiliates and business partners. The CFPB said entities "will want to identify whether the Nonbank Registration Regulation impacts their affiliate businesses or other business partners, and how best to coordinate to comply with the Nonbank Registration Regulation" as well as identify whether their affiliated businesses or other business partners are in the registry.   

The registration period for the first covered entity type, Larger Participant CFPB-Supervised Covered Nonbanks, opens October 14 and closes January 14, 2025.