On July 7, 2020 the CFPB issued a Final Rule to amend its requirements regarding Payday, Vehicle Title, and Certain High-Cost Installment Loans (12 CFR 1041). We blogged about the proposed rule and history of the regulation last year.
The 2017 Rule had two primary parts – the “Mandatory Underwriting Provisions” (effective 11/19/2020) and the “Payment Provisions” (effective 08/19/2019). The 2020 Final Rule revokes the “Mandatory Underwriting Provisions” requirements.
The Statement on Supervisory and Enforcement Practices Regarding Certain Large Loans Under the Regulations for Payday, Vehicle Title, and Certain High-Cost Installment Loans includes a reminder that “(a)s of the release of this Statement, the Rule, including the Payment Provisions, has been stayed by a federal district court.” Thus, the compliance date for the Rule and amendments has been stayed until further order of the court.
Payday Lending Rule FAQs on covered loans and payment transfers
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