In April 2024, Andrew Bigart published “What digital consumer payment companies need to know about CFPB supervision” in Compliance Today. The following is an excerpt:
Following years of market research into the fintech and payments industries, in November 2023, the Consumer Financial Protection Bureau (CFPB) announced a proposed “larger participant” rulemaking to define the market for general-use digital consumer payment applications.[1] The proposed rule would subject companies that provide “payment apps,” “person-to-person apps,” “P2P apps,” and similar applications to CFPB supervision and examination, provided that the companies meet certain size thresholds.
The CFPB is the primary supervisor of consumer financial products and services offered by nonbank entities. The prospect of a CFPB examination can be daunting: voluminous document requests, on-site visits, and the potential for remediation and penalties if the examiners identify significant deficiencies.
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