We discuss recent and ongoing enforcement activity of the PA AG involving consumer financial services. Our conversation focuses on activity directed at: auto title lenders for alleged violations of PA usury law; national banks for alleged CARD Act violations; furniture retailers for alleged “hang tag” law violations; home sellers for alleged violations of mortgage laws
auto title
CFPB enters into consent order with small-dollar lender to settle alleged TILA and UDAAP violations
The CFPB announced that it has entered into a consent order with Main Street Personal Finance, Inc. and two subsidiaries (Main Street), each a small-dollar lender, to settle the CFPB’s allegations that Main Street (1) violated the Truth in Lending Act and the CFPA’s UDAAP prohibition by underdisclosing the finance charge on auto-title loans entered…
CFPB enters into consent order with small-dollar lender to settle alleged TILA and UDAAP violations arising from finance charge disclosure on auto title pledges
The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the CFPA’s UDAAP prohibition by underdisclosing the finance charge on auto title pledges entered into with Mississippi consumers.
According…
CFPB final payday/auto title/high-rate installment loan rule published in Federal Register
The CFPB’s final payday loan rule was published in today’s Federal Register. Lenders covered by the rule include nonbank entities as well as banks and credit unions. In addition to payday loans, the rule covers auto title loans, deposit advance products, and certain high-rate installment and open-end loans. For a summary of the rule,…
CFPB enters into consent order with auto title lender
The CFPB announced that it has entered into a consent order with TMX Finance, LLC to settle allegations that the company did not provide sufficient information to consumers about the terms of auto title loans, pawns or pledges, and engaged in unfair collection practices. The consent order requires TMX Finance to pay a $9 million…
CFPB announces enforcement actions against auto title lenders
The CFPB announced that it has filed administrative enforcement actions against five Arizona auto title lenders for alleged violations of Truth in Lending Act advertising requirements. According to the CFPB, the lenders violated TILA by advertising a periodic interest rate for their loans on their websites without advertising a corresponding annual percentage rate. As examples,…
CFPB issues proposed payday/auto title/high-rate installment loan rule
As expected, the CFPB issued its proposed payday loan rule, in a release running 1,334 pages. The CFPB also issued a fact sheet summarizing the proposal. On June 15, 2016, from 12 p.m. to 1 p.m. ET, we will hold a webinar on the proposal: The CFPB’s Proposed Payday/Auto Title/High-Rate Installment Loan Rule: Can…
The CFPB’s auto title loan report: last step to a payday/title loan proposal?
The CFPB has issued a new report entitled “Single-Payment Vehicle Title Lending,” summarizing data on single-payment auto title loans. The latest report is the fourth report issued by the CFPB in connection with its anticipated rulemaking addressing single-payment payday and auto title loans, deposit advance products, and certain “high cost” installment and open-end loans. The…
CFPB Consumer Advisory Board to meet on June 18
The CFPB has announced that a summer meeting of its Consumer Advisory Board is scheduled for June 18, 2015 in Omaha, Nebraska. Director Cordray is slated to attend the meeting.
The meeting will focus on trends and themes in consumer financial markets and recent proposals related to payday loans, auto title loans, and other longer…
CFPB holds hearing on payday and auto title loans in Richmond, VA
On March 26, the CFPB held a public hearing on payday and auto title lending, the same day that it released proposed regulations for short-term small-dollar loans. Virginia Attorney General, Mark Herring gave opening remarks, during which he asserted that Virginia is perceived as the “predatory lending capital of the East Coast,” suggesting that payday…