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A CSBS White Paper: Reengineering Nonbank Supervision

About This Paper (updated February 2020)

The Conference of State Bank Supervisors (CSBS) has developed this paper, Reengineering Nonbank Supervision, to serve two primary purposes. First, as a stakeholder awareness document covering state supervision of the nonbank marketplace; and second, as a change document or roadmap to assist state supervisors in identifying the current state of supervision and making informed changes to state supervisory processes. The paper is comprised of several standalone chapters that together will cover the industry supervised by state nonbank financial regulators, the existing system of supervision for nonbanks, and the challenges and opportunities for state supervisors in reengineering that system. 

This first chapter, "Introduction to the Nonbank Industry," provides a broad overview of industry participants that are the primary focus of state nonbank supervisors. We combine these sometimes unlike participants into a single industry of nonbanks, due more to jurisdictional coverage and supervisory constructs than similarities between the participants themselves. The common theme is that all of these participants provide or facilitate consumer products and services and fall under the authorities granted to nonbank supervisors (discussed in Chapter Two).

State financial regulators are the primary regulators of nonbanks operating within the United States. Together, they have forged a series of initiatives to modernize nonbank licensing and supervision. This research paper will contribute research and engage discussion on possible actions that might be taken. 

Chapter One: Introduction to the Nonbank Industry

Chapter Two: Overview of State Nonbank Supervision

Chapter Three: Overview of Nonbank Mortgage

Chapter Four: Overview of Money Services Business

Chapter Five: Overview of Debt Collection

Chapter Six: Overview of Nonbank Consumer Finance

This page will be updated with subsequent chapters.


The paper is staff-developed under the direction of the CSBS Non-Depository Supervisory Committee. In creating this paper, we have interviewed over 80 subject matter experts from industry and state government. Acknowledgement of these experts, as well as identification of authors and support staff, can be found here. 

Comments and questions on the content of this paper can be directed to:
Chuck Cross, CSBS Senior Vice President of Nonbank Supervision and Enforcement, [email protected]