Dear Director Chopra:
We appreciate the opportunity to respond to the CFPB’s proposal to require certain nonbank
covered person entities to report the existence of certain public agency and court orders to a Bureau registry. The proposal also would require certain supervised nonbanks to submit annual written statements regarding compliance with each underlying order, signed by an attesting executive who has knowledge of the entity’s relevant systems and procedures for achieving compliance and control over the entity’s compliance efforts. The Bureau explains that, consistent with the Consumer Financial Protection Act, “the Bureau implements a risk-based supervision program under which it prioritizes nonbank covered persons for supervision in accordance with its assessment of risks posed to consumers” and has issued this proposal in furtherance of that risk-based approach.
 88 Fed. Reg. at 6090.