Multistate Enforcement Protocol and EPIC Working Group

Description of the Multistate Enforcement Protocol and EPIC Working Group.

The CSBS Board of Directors approved the Multistate Enforcement Protocol on August 26, 2025. The protocol is a very high-level document, and the purpose of it is to establish a voluntary mechanism to administer multistate enforcement actions. In December 2025, the Board approved the 2026 through 2030 strategic plan with a measure to develop processes in coordination with the sister state nonbank regulatory associations to implement the protocol.

A working group called EPIC (Enforcement Protocol Implementation Committee) has been established to draft processes to help implement the protocol. EPIC includes approximately 15 members with representatives from NACA, NACARA, AARMR, and the MTRA. EPIC started meeting in January to develop the processes under the protocol, and it will continue meeting biweekly until the processes are developed and are ready to pilot.

Alongside the Multistate Enforcement Protocol, CSBS has begun developing an initial workflow to house multistate enforcement actions.