Delayed Final Payday Rule

On June 6, 2019, the CFPB issued the latest final Payday Lending Rule formally delaying the compliance dates for the mandatory underwriting provisions and making technical corrections to the payment provisions of the original Rule.  The compliance dates are set out in a new section, §1041.15, of the Rule.  The Executive Summary notes that the Bureau “continues to consider comments … Read More

Payday Lending Rule Update

Payday, Vehicle Title, and High-Cost Installment Lending Rule (Payday Lending Rule)   Status & Timeline Currently, the Payday Lending Rule is 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) Compliance with the Rule is not required until the court-ordered stay is lifted. October 5, 2017 – The … Read More

Payday Loan Rule – Part 4 of 3; Submitting Comments

Payday Loan Rule – Part 4 of 3, Submitting Comments The CFPB is accepting comments on its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule, released June 2, 2016.  Comments on the proposed rule must be submitted by September 14, 2016. You may submit comments, identified by Docket No. CFPB-2016-0025 or RIN 3170–AA40, by any of the following … Read More

Proposed Payday Loan Rule – Part 2

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

Proposed Payday Loan Rule – Part 1

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