As anticipated, the Department of Defense’s proposed regulations to implement provisions of the Military Loan Act added by the 2013 Defense Authorization Bill would significantly expand MLA coverage. The proposed revisions would limit interest charged to servicemembers and their dependents on all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards and require creditors to screen all applicants against a DoD database before offering such products with rates greater than 36 percent. … Continue Reading
Heather S. Klein
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CFPB Payday Loan Rulemaking is Imminent and Will Target Repeated Borrowing
By Heather S. Klein on
The CFPB has marshaled data against what it sees as a sustained use problem by payday loan borrowers and is “in the late stages” of drafting rules to limit payday loan borrowing, according to Director Cordray’s remarks prepared for today’s field hearing.
It appears that in the near future the Bureau will issue a notice of proposed rulemaking in which it concludes that repeated payday loan borrowing is “unfair” or “abusive” under the Dodd-Frank Act.… Continue Reading
A future without dealer participation and what it should look like, according to the CFPB
By Heather S. Klein on
At the CFPB’s auto finance forum on November 14, Director Cordray and other CFPB officials reiterated their distaste for dealer finance charge participation as a method of dealer compensation in the indirect auto finance market. (As readers know, dealer participation involves dealers setting the finance charge above the rate at which a bank or finance company has indicated it might be willing to buy a contract; the dealer keeps a portion or all of the difference.) … Continue Reading
CFPB expands complaint database
By Heather S. Klein on
Posted in CFPB General, Regulatory and Enforcement
On Friday, the CFPB announced that it had expanded its public Consumer Complaint Database to include complaints about credit reporting and money transfers. Simultaneously, the CFPB announced that complaints in its public database are searchable by state.
The CFPB uses complaints its receives to prioritize and prepare for investigations and examinations.… Continue Reading
CFPB proposes amending credit card ability-to-pay rule
By Heather S. Klein on
Posted in Credit Cards, Regulatory and Enforcement
The CFPB has released its proposed ability-to-pay rule. The proposed rule would amend the section of Regulation Z that currently provides that a credit card issuer must not open a credit card account or increase any limit on the account unless the card issuer considers the consumer’s independent ability to make the required minimum periodic payments based on the consumer’s income or assets and current obligations.… Continue Reading