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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 and auto title lenders were a large part of the problem.… Continue Reading

The CFPB has announced that it will be holding a field hearing on payday loans on
March 25, 2014 in Nashville, Tennessee.  The event will feature remarks by Director Cordray and testimony from consumer groups, industry members, and the general public. 

The CFPB’s rulemaking agenda issued at the end of last year included “prerule activities” concerning payday loans and deposit advance products targeted for this month. … Continue Reading

We found much to criticize when the CFPB issued its White Paper this past April on payday and deposit advance loans.  However, we remain hopeful that the CFPB will make good on its commitment that any rule-making on these matters will be evidence-based. 

Unfortunately, the OCC and FDIC have not taken that approach. … Continue Reading

As suggested by prior blog posts, I am no fan of the direction the CFPB, OCC and FDIC seem to be going with respect to payday and deposit advance loans. These agencies have all signaled a willingness to prohibit these loans without regard to Dodd-Frank’s definitions of the terms “unfair” and “abusive” and without applying the cost-benefit analysis required by the statutory language.… Continue Reading

Coincidentally (or not), on the same day the CFPB launched its overdraft fee initiative, previously discussed, 250 national, state and community organizations and individual activists wrote the heads of the CFPB and the federal banking agencies to attack deposit advance products. Both the CFPB in its payday lending exam manual and the authors of this letter treat deposit advance loans as a kind of payday loan.… Continue Reading