Over the past two years, the Consumer Financial Protection Bureau (CFPB) has been aggressively seeking to expand the range of companies over which it has examination authority. These efforts included the CFPB's announcement in 2022 of its intention to use a previously "dormant" authority to conduct regulatory examinations of nonbank financial companies when they pose risks to consumers and a rule the CFPB proposed in November 2023 that seeks to modify existing guidelines by adding provisions that specifically target "larger participants" within the digital wallet and payment application spheres, subjecting these nonbank companies to comprehensive examinations.