Joint Trades Comments on CFPB Proposal Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders

The undersigned trade associations appreciate the opportunity to submit comments to the Consumer Financial Protection Bureau (“CFPB”) regarding its proposal to create a registry of nonbank covered persons subject to certain agency and court orders (the “Proposed Rule”).

The U.S. consumer financial services market serves consumers well, enabling families to pursue the American dream while also meeting life’s unexpected challenges. It is one of the most highly regulated markets in the world. Consumer financial services companies invest substantial sums in ensuring compliance with a wide range of relevant statutes and regulations. Dedicated professionals work every day to serve consumers while maintaining scrupulous compliance with the law. This work is complicated, time-consuming, and expensive. Complex and opaque regulations make compliance a challenging endeavor. Indeed, companies regularly ask the CFPB for assistance in determining what the law requires.