Payday Loans

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.

Unofficial Redline

Executive Summary

Small Entity Compliance Guide

Payday Lending Rule FAQs on covered loans and payment transfers


Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations

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