6 minute read | March.18.2026
Regulators and industry participants gathered at the 2026 Nationwide Multistate Licensing System (NMLS) Annual Conference & Training in Orlando to discuss emerging supervisory priorities and regulatory developments affecting the consumer finance industry. Conversations throughout the conference highlighted several themes, including evolving CFPB enforcement activity, growing scrutiny of innovative consumer finance products, expanded use of supervisory technology and the implementation challenges associated with new federal legislation such as the GENIUS Act.
Members of our team were on site for the event and below are several notable takeaways from conference sessions relevant to consumer finance companies, money services businesses and mortgage market participants.
Future enhancements to the NMLS focus on company and MLO relationships, licensee and regulator communication, and overall user experience improvements. Currently, the NMLS has rolled out a new interface for Form MU4 Individuals. On April 18, the NMLS will roll out updated NMLS Disclosure Questions for Form MU4 and Form MU2 individuals. These updates to the Disclosure Questions will impact all mortgage loan originators and all individuals that complete the MU2 Form (control persons, including company owners and officers, sole proprietors, qualifying individual and branch managers). Once the new disclosure questions are implemented, a company will not be able to submit a Form MU1 without the Form MU2 individuals having answered the updated questions.
The NMLS Ombudsman holds a meeting twice a year to provide a venue for discussing industry issues or concerns regarding the NMLS. The February meeting at the annual NMLS Conference addressed concerns about how regulators and the industry might respond to a large-scale failure and the systemic risks that could arise from the collapse or distress of a major market participant.
Industry requests were also raised for consideration of the following items:
The CFPB is still operating under an acting director and, since the beginning of the year a number of investigations have restarted, signaling some level of continued enforcement activity at the Bureau. It also appears that consumer complaints processing continues, as these can be submitted through the CFPB’s database and are forwarded to companies that are the subject of those complaints. Further, the CFPB does have an examination calendar, and virtual exams may start in April 2026. Nevertheless, some states have increased consumer protection enforcement to address perceived gaps created by reduced CFPB activity.
Three areas of significant CFPB rulemaking include:
Multiple sessions throughout the event focused on policy updates and how technology is being deployed by regulators, as well as the risks that increased use of emerging technologies can pose to financial services companies. A few important points from these sessions include:
As new products develop and become widely adopted, it presents questions about where these products may fall within the regulatory oversight spectrum. A few examples include:
The federal GENIUS Act was signed into law and becomes effective January 2027, providing a short runway for a new national regulatory framework for stablecoins. The Act established federal baseline standards for stablecoins and imposes greater scrutiny of reserves, but retains state licensing, examination and enforcement authority. This creates gaps in potential readiness for both regulators and market participants:
Looking ahead, examiner training and interstate coordination along with early guidance by state regulators may help close the supervisory gaps. From the industry perspective, mapping state exposure and early engagement with reserve and reporting systems may be helpful as entities plan for transitional supervision.
Bank-fintech partnerships and supervisory oversight are also top of mind, with a number of recent enforcement actions in this space, especially around AML. Given differing priorities across entities, risk management and compliance standards should be set by the bank partner. Importantly, a reasonableness standard in the AML program should be considered to ensure that the bank-fintech partnership does not carry unnecessary or burdensome requirements. States are increasingly focused on partnerships, ensuring standards are met. However, even as the pace of financial innovation accelerates, regulators may not have access to the latest supervisory technology resources due to procurement laws and other factors.
As partnerships develop, scale and end, entities should consider successor banks and plans for termination. Ensuring ongoing compliance is important, because even if regulatory oversight increases or becomes more relaxed, or technology causes delays, there is always a look-back period during exams that entities will have to take into account.
The discussions at the NMLS conference reflect broader trends shaping the consumer finance regulatory environment, including increased state-level engagement, evolving federal enforcement priorities and growing regulatory attention to emerging fintech products. Market participants should remain attentive to these developments as regulators continue adapting supervisory frameworks to address innovation in financial services.
If you would like to discuss any of these developments or their potential implications for your business, please contact the authors or your usual Orrick contact. Senior Paralegal Kimberly McCready contributed to this article.