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Earlier this week, by a party-line 34-26 vote, the House Financial Services Committee passed H.R. 4861, a bill seemingly intended to ease restrictions on short-term, small-dollar loans made by depository institutions.  The bill is part of the efforts of House Republicans to provide greater regulatory relief to banks than would be provided by S.… Continue Reading

Hours after the CFPB released its final payday/auto title/high-rate installment loan rule on October 5, 2017, the OCC rescinded its guidance on deposit advance products.  That guidance, entitled Supervisory Concerns and Expectations Regarding Deposit Advance Products published in November 2013 (OCC Bulletin 2013-40), and substantially identical guidance issued by the FDIC on the same day, had effectively precluded banks subject to OCC and FDIC supervision from offering deposit advance products. … Continue Reading

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 Industry Adapt to the New World Order? … Continue Reading

The CFPB has moved a step closer to issuing payday loan rules by releasing a press release, factsheet and outline of the proposals it is considering in preparation for convening a small business review panel required by the Small Business Regulatory Enforcement Fairness Act and Dodd-Frank.  The CFPB’s proposals are sweeping in terms of the products they cover and the limitations they impose. … Continue Reading

In an effort to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, the CFPB has released a report entitled “The extension of high-cost credit to servicemembers and their families.”  The DoD proposal would revise the scope of “consumer credit” subject to MLA restrictions to include, regardless of term or amount, all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards.… Continue Reading

In the latest semi-annual update of its rulemaking agenda, the CFPB officially confirmed that it plans to propose a rule to define “larger participants of a market for auto lending.”  The official confirmation follows statements made by Steven Antonakes at a Consumer Bankers Association meeting in April 2014 that the CFPB’s next larger participant rule would relate to auto finance. … Continue Reading

Jeff Sovern and I come at most issues from different sides of the street but I want to credit him for the open mind he showed in his recent blog post on deposit advance loans.  Unlike many of his colleagues in the consumer advocacy business (to say nothing of the staff at the FDIC and OCC), Jeff is not prepared to eliminate deposit advance loans before someone gives serious consideration to “what would the borrowers who are now taking out such loans do if they could no longer get them.” … Continue Reading