Financial Firms: What the New CFPB Nonbank Registry Rule Requires

Financial firms that qualify as nonbank covered persons and are subject to a public agency or court order have a new registry filing to make, effective September 16, 2024. A final rule from the Consumer Financial Protection Bureau, published July 8, 2024 in the Federal Register and cited as 89 FR 56028, requires certain nonbank covered persons subject to specified final public orders to report the existence of those orders, and related information, to a Bureau registry.

This brief walks through what the rule changes, who it reaches, what to check before ongoing compliance obligations come due, and how the rule fits the broader window of federal rulemaking financial firms are tracking this year. It is written for compliance, legal, and operations teams who need the substance of the rule without reading the full Federal Register notice themselves. The obligation comes first; everything else is context.

Before this rule, an agency or court order against a nonbank provider of consumer financial products or services existed as a record wherever the issuing agency or court kept it — scattered across whatever docket or enforcement system originated it. The registry the Bureau built under this rule consolidates that information into a single, Bureau-maintained reference, so a covered order's existence and status can be found in one place rather than reconstructed case by case from separate agency records.

Key Takeaways

• A final rule from the Consumer Financial Protection Bureau (89 FR 56028) requires certain nonbank covered persons to report specified agency and court orders to a Bureau registry, effective September 16, 2024.

• The rule is issued under the Consumer Financial Protection Act of 2010 and reaches nonbank covered persons subject to certain final public orders connected to a consumer financial product or service.

• Certain supervised nonbanks are also required to file annual reports on their compliance with registered orders.

• The rule amends 12 CFR Part 1092 and carries RIN 3170-AB13.

• Registration is not a one-time filing; supervised nonbanks with ongoing obligations under a registered order have a recurring annual reporting duty.

What This Rule Actually Does

The Consumer Financial Protection Act of 2010 gives the Bureau authority to require reporting related to orders issued against nonbank providers of consumer financial products or services. The rule effective September 16, 2024 uses that authority to require certain nonbank covered persons that are subject to specified final public orders — orders obtained or issued by a government agency in connection with the offering or provision of a consumer financial product or service — to report the existence of the order, and related information, to a registry the Bureau maintains.

The rule also creates an ongoing obligation for certain supervised nonbanks: beyond the initial report of a covered order's existence, those firms are required to file annual reports addressing their compliance with the terms of a registered order. The registry itself functions as a Bureau-maintained record of nonbank entities operating under a public order tied to consumer financial products or services, giving the Bureau and the public a centralized reference rather than a scattered set of individual agency and court records.

Firms that are already subject to a qualifying agency or court order need to determine whether that order falls within the rule's scope and, if so, complete the initial registry report and plan for the recurring annual compliance report where it applies.

The rule's two-part structure — an initial report of the order's existence, plus recurring annual compliance reporting for supervised nonbanks — means the obligation does not end once the first registry entry is filed. A firm that reports an order and then treats the registry as a closed matter can miss the ongoing reporting cycle the rule builds in for supervised nonbanks operating under a registered order, which is a separate and continuing requirement rather than a one-time formality.

Who Is Affected

The rule reaches nonbank covered persons — nonbank providers of consumer financial products or services — that are subject to certain final public orders issued or obtained by a government agency in connection with offering or providing those products or services. Supervised nonbanks among that group carry the additional annual reporting obligation.

The rule's reach depends on whether a firm is currently subject to a final public order connected to a consumer financial product or service — firms with no such order outstanding have nothing to report, while firms with one or more qualifying orders need a process for identifying them and keeping the registry current as order status changes.

Firms operating across multiple business lines or subsidiaries face a further wrinkle: a qualifying order against one subsidiary or line of business does not necessarily put every affiliated entity in scope, but it does mean the group as a whole needs a consistent way of tracking which entity holds which order, so a registry report is not filed against the wrong corporate name or missed entirely because responsibility for it was unclear internally.

What Financial Firms Should Do Before the Deadline

The rule requires certain nonbank covered persons subject to specified agency and court orders to report those orders to the Bureau's registry, effective September 16, 2024. Firms need to determine whether any order they are subject to qualifies, complete the required report, and — where the firm is a supervised nonbank — build a recurring process for the annual compliance report tied to a registered order.

• Inventory every final public order the firm is currently subject to, from any government agency, connected to a consumer financial product or service.

• Determine which of those orders falls within the rule's registry-reporting scope.

• File the required registry report for each qualifying order, including the related information the rule calls for.

• Identify whether the firm is a supervised nonbank subject to the rule's additional annual reporting requirement.

• Build a calendar for the recurring annual compliance report, rather than treating registration as a single event.

• Monitor for new orders going forward, since a newly issued qualifying order creates a new reporting obligation.

Operationalizing Nonbank Registry Reporting at Volume

For a firm managing more than a handful of agency or court orders across business lines, keeping the Bureau's registry current — and staying ahead of the annual compliance-report cycle for registered orders — is easy to do once and lose track of as orders are added, modified, or resolved. US Tech Automations builds this kind of check as a standing agentic workflow rather than a one-time filing: order status and registry reporting are tracked consistently, and the workflow surfaces an upcoming annual report automatically instead of waiting for someone to notice a filing deadline has passed.

How This Fits the Broader Regulatory Window

This rule is one entry in a much larger set of federal compliance obligations financial firms are tracking this year. It sits inside a point-in-time index of 342 U.S. federal rules published July 1, 2024 – July 9, 2026 by 10 agencies governing our covered industries — a reminder that a single registry-reporting requirement rarely arrives alone, and that a firm tracking only the rule in front of it is likely missing several others moving on a similar clock.

Firms that would rather build order-tracking and registry reporting once and reuse it across every future CFPB order can review current plans from US Tech Automations.

Frequently Asked Questions

When does the nonbank registry rule take effect?

The rule is effective September 16, 2024. Nonbank covered persons subject to a qualifying agency or court order need to report that order to the Bureau's registry from that date forward, per the rule as published.

Who counts as a "nonbank covered person" under this rule?

The rule reaches nonbank providers of consumer financial products or services that are subject to certain final public orders obtained or issued by a government agency in connection with offering or providing those products or services.

What has to be reported to the registry?

The rule requires reporting the existence of a qualifying order and related information to the Bureau-maintained registry, so the Bureau and the public have a centralized record of nonbank entities operating under such orders.

Is registry reporting a one-time filing?

Not for every firm. Certain supervised nonbanks are also required to file annual reports on their compliance with a registered order, in addition to the initial report of the order's existence.

Which CFR part does this rule amend?

The rule amends 12 CFR Part 1092 and carries RIN 3170-AB13.

Does a qualifying order against one subsidiary automatically cover the whole corporate group?

The rule reaches the nonbank covered person subject to the qualifying order. Firms with multiple subsidiaries or business lines need a consistent internal process for tracking which specific entity holds a qualifying order, since responsibility for the registry report follows the entity the order applies to.

What happens after the initial registry report is filed?

For nonbanks not subject to the rule's supervised-nonbank annual reporting requirement, the initial report may be the extent of the obligation for that order. Supervised nonbanks subject to a registered order have the additional, recurring duty of filing annual compliance reports for as long as that requirement applies.

Where can I read the official rule?

The rule is cited as 89 FR 56028, was published July 8, 2024 in the Federal Register, and is effective September 16, 2024. The current regulatory text is available through the eCFR at 12 CFR Part 1092.

Related guidance

For adjacent obligations financial firms are tracking this cycle, see our guides on the registration rule for index-linked annuities, Form N-PORT and Form N-CEN reporting, and automated valuation model quality-control standards.

Disclaimer

This article is provided for informational purposes only and does not constitute legal or tax advice. Reading it does not create an attorney-client relationship. Regulatory obligations turn on facts specific to each institution, and the law can change. Before acting on anything described here, consult a qualified attorney or tax advisor who can evaluate your particular circumstances.

Every date, citation, RIN, CFR reference, and figure in this post is copied verbatim from the Federal Register and eCFR as of the snapshot date. Nothing is estimated, modeled, or extrapolated. This is not legal or tax advice.

Last reviewed: July 9, 2026.

Source: U.S. Federal Register (89 FR 56028); current text via eCFR, 12 CFR Part 1092.