1041 Payday, Auto Title, and Balloon-Payment Loans Rule

On October 5, 2017, the CFPB released its anticipated 1690-page Rule regarding payday, auto title, and balloon-payment loans.  The Rule, while pared down from the June 2016 CFPB’s proposed rule, still covers the ability-to-repay and underwriting requirements, payment restrictions and requirement, and new information reporting for covered loans.  (A version of the Rule, with Official Interpretations incorporated is available here.) … Read More

Proposed Payday Loan Rule – Part 3

The CFPB released its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More