Delivering the keynote address last week at the Consumer Federation of America’s 2022 Consumer Assembly, CFPB Deputy Director Zixta Martinez indicated that the CFPB “is taking a close look” at “‘rent-a-bank’ schemes.”

Deputy Director Martinez commented that “[s]ome lenders attempt to use [relationships with banks] to evade state interest rate caps and licensing laws by

In opposing efforts by federal and state lawmakers to impose rate caps on small-dollar loans, industry representatives have pointed out the harm that a rate cap can create for consumers, particularly those with less than perfect credit, by reducing access to credit.  These concerns are often dismissed by consumer advocates with the argument that banks

The Fifth Circuit has scheduled oral argument for May 11, 2022 in the appeal filed by the trade groups challenging the payment provisions in the CFPB’s 2017 final payday/auto title/high-rate installment loan rule.

The trade groups have appealed from the district court’s final judgment granting the CFPB’s summary judgment motion and staying the compliance date

Hawaii recently enacted significant changes to its small-dollar lending law that repeals existing Hawaii law on deferred deposits and creates a new regime for installment loans.  Although H.B. 1192 took effect on July 1, the repeal of the existing law on deferred deposits is effective January 1, 2022 as is the new licensing requirement for

The CFPB and the two trade groups challenging the CFPB’s 2017 final payday/auto title/high-rate installment loan rule (2017 Rule) have filed responses with the Texas federal court  regarding a compliance date for the 2017 Rule’s payment provisions.

The responses reply to the briefs filed by the parties following the court’s issuance of an order requesting

The CFPB has issued a no-action letter (NAL) to a bank to facilitate the bank’s ability to offer a small-dollar loan product.

In May 2020, the CFPB issued a No-Action Letter Template for small-dollar loan products (Template) offered by insured depository institutions or credit unions subject to the Bureau’s supervisory and enforcement jurisdiction (i.e., entities