The CFPB recently published materials on the Payday Lending Rule and it is somewhat confusing. Within these materials, it refers to certain effective dates but I was under the impression that due to the pending court ordered stay between the CFSA v. CFPB in Texas, there still is no compliance effective date for this rule. Is that correct or are there certain provisions that we should be following?
“The Payday Lending Rule became effective on January 16, 2018. However,the Rule’s compliance date for the payment-related requirements is August 19, 2019. Thus, by its terms,the Rule does not require lenders to comply with the Rule’s payment-relatedrequirementsuntil August 19, 2019. See 12 CFR 1041.15. The compliance date, however, is currently stayed pursuant to a court order issued in Community Financial Services Association v. CFPB, No. 1:18-cv-00295 (W.D. Tex. Nov. 6, 2018). As a result, lenders have no obligation to comply with the Rule until the court-orderedstay is lifted.” – CFPB Small Entity Compliance Guide, p. 8, https://files.consumerfinance.gov/f/documents/cfpb_payday_small-entity-compliance-guide.pdf