The Equipment Leasing & Finance Association (ELFA) last week submitted comments to the Consumer Financial Protection Bureau (CFPB) regarding its proposed rule on supervisory designation of nonbank entities.

Representing a broad spectrum of nonbanks, as well as banking divisions and subsidiaries engaged in the specialized field of asset-based equipment finance, ELFA expressed support for the CFPB’s efforts to clarify the definition of “risks to consumers” in the context of nonbank supervision. In its comments, ELFA also urged the Bureau to consider additional threshold standards when overseeing banks and issuing guidance for financial institutions.

Among its key recommendations, ELFA encouraged the CFPB to align bank supervisory thresholds with Small Business Administration (SBA) size standards and to exempt financial banking institutions with fewer than 500 employees from certain reporting requirements. The association also highlighted the operational complexity many members face when utilizing vendor finance arrangements, and it emphasized the importance of regulatory coordination, particularly with state and other federal agencies when crafting future rules.

Finally, ELFA stressed the need for a clear and consistent definition of “risks to consumers” to ensure transparency and regulatory certainty across the industry.

ELFA views the proposed rule as a positive step forward and will continue to monitor the Bureau’s actions moving ahead. The full letter can be viewed here.