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ARM industry members who are operating under enforcement orders from the CFPB or any other federal or state agency are facing submitting company information as well as copies of the orders on the CFPB’s Nonbank Registry. Large-market participants get to go first and may register starting October 16, assuming that the registration website is available by that date. In the meantime, because the CFPB has published its Nonbank Registration Filing Instructions Guide, anyone who is bound by the rule can prepare for their submission by compiling the information necessary for registration as a user on the Registry site, and for the actual registration of their Order(s). This 71-page behemoth work instruction seeks to help registrants to register their company accurately and completely, and then to properly identify, classify, and upload their relevant orders.
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