In a joint letter submitted to the CFPB in response to their request for comment on which larger participants in the nondepository market should fall under CFPB oversight, The Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators (AARMR) offered a number of new ideas for how the new agency should approach the issue. One suggestion that we found especially interesting:

The CFPB should require all covered persons, as defined, to be registered with the CFPB in each State in which they do business.

Exactly what this type of registration would entail remains unclear, but such a shift could mean major changes to the licensing process as we know it.

One reminder: A majority of states have chosen to meet consumer demand for payday advances with balanced, responsible regulation for their constituents. Thirty-two states have recognized the need for a small dollar, short-term credit source for their constituents and enacted legislation that protects consumers and their access to credit, while allowing law-abiding payday lenders to operate.