“Waiting for the CFPB’s arbitration study” isn’t the title of a new play but it does describe the study’s status as we enter the final hours of 2014.
Since the CFPB sent letters to payday lenders in August 2014 demanding copies of certain of their standard loan agreements for use in connection with the arbitration study, I have been skeptical about continued statements from CFPB officials that the study would be completed by the end of 2014. My skepticism appears to have been justified and I am now expecting the study to be released in early 2015.
The CFPB is conducting the study under Section 1028 of Dodd-Frank. In April 2012, it published a request for information about the scope, methodology and data sources for the study. In September 2013, the CFPB issued orders to obtain standard checking account agreements for the study. In December 2013, the CFPB published preliminary study results.