Archive

FINAL PAYDAY LENDING RULE PUBLISHED

On July 7, 2020, the Consumer Financial Protection Bureau (CFPB) published a final rule, and related materials, related to the Payday lending and other small dollar products. The Payday Lending rules have been unfolding for several years. The final rule, implemented as Regulation OO, rescinds the mandatory underwriting provisions of the 2017 rule after re-evaluating the legal and evidentiary bases for these provisions and finding them to be insufficient. The final rule does not rescind […]

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STATUS OF PAYDAY RULE LITIGATION

A new joint status report was filed on Friday April 24, 2020 with the Texas federal district court hearing the lawsuit filed by two trade groups challenging the Consumer Financial Protection Bureau’s(CFPB) final Payday, Vehicle Title, and Certain High-Cost Installment Loans rule (Payday Rule). The report notes that the CFPB “is continuing to make progress” on its proposed rulemaking to rescind the Payday Rule’s ability-to-repay (ATR) provisions and references the CFPB’s statement in its Fall […]

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PAYDAY LOAN RULES APPLY TO YOU – ARE YOU READY?

The Payday, Vehicle Title, and Certain High-Cost Installment Loans (Payday Loan) Rule has been unfolding for years. Parts of the rule officially took effect on August 19, 2019; the Consumer Financial Protection Bureau (CFPB) has delayed the underwriting rules until November 19, 2020, and has further proposed eliminating those rules altogether. The August 19 date has been temporarily postponed by a court order. Some lenders need to build a comprehensive compliance management system (CMS) to […]

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CFPB STATEMENT ON PAYDAY RULE

On January 16, 2018 the Consumer Financial Protection Bureau (CFPB) issued the following statement on the Payday Rule: “January 16, 2018 is the effective date of the Bureau of Consumer Financial Protection’s final rule entitled “Payday, Vehicle Title, and Certain High-Cost Installment Loans” (“Payday Rule”).  The Bureau intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule. Although most provisions of the Payday Rule do not require compliance until August […]

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FINAL PAYDAY RULES

On October 5, 2017 the Consumer Financial Protection Bureau (CFPB) made available a final new rule, 12 CFR Part 1041 (Regulation OO), for Payday, Vehicle Title and Certain High-Cost Installment Loans. The 1,690 page rule is, for the most part, effective 21months after publication in the Federal Register. The rule is complex and controversial. The development of the rule involved over five years of research, outreach, and a review of more than one million comments […]

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