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Last month, Ballard Spahr submitted two letters to the CFPB, critiquing the payment provisions of the CFPB’s final payday/auto title/high-rate installment loan rule (the “Payment Provisions”).  Last Friday, the Bureau delayed the implementation date of the rule’s mandatory underwriting provisions by 15 months, to November 19, 2020.  However, the Payment Provisions are scheduled to go…

The CFPB and the two industry trade groups that filed a lawsuit in a Texas federal district court challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule) filed a new status report with the court on March 8 to follow up on their March 1 status report.

The new status report sets…

The CFPB has issued a new small entity compliance guide: “Payday, Vehicle Title and High-Cost Installment Lending Rule: Payment-Related Provisions.”

The CFPB has proposed to revise its final payday/auto title/high-rate installment loan rule to rescind the rule’s ability-to-repay (ATR) provisions in their entirety and to delay the compliance date for the ATR provisions…

The CFPB is proposing to rescind the ability-to-repay provisions of its payday loan rule and delay the provisions’ compliance date while leaving in place the rule’s troublesome payment provisions and their August 19 compliance date.  In this week’s podcast, we look at the CFPB’s rationale for rescinding the ATR provisions, what the payment provisions require…

The CFPB announced that it has entered into a settlement with the owners of payday loan retail outlets that operated under the name “Cash Tyme” in seven states to resolve alleged violations of the Consumer Financial Protection Act, the Gramm-Leach-Bliley Act/ Regulation P, and the Truth in Lending Act/ Regulation Z.  The consent order requires…

The CFPB has entered into a proposed settlement with a group of corporate and individual defendants who were alleged to have engaged in unlawful conduct in connection with offering “short-term loans to consumers located in the United States through a network of affiliated companies located in Canada and Malta.”

The settlement is intended to resolve…

By an overwhelming vote (approximately 1,4270,000 million to 433,000), Colorado voters passed Proposition 111, a ballot initiative that places a 36 percent APR cap on payday loans.  The question presented to voters was:

Shall there be an amendment to the Colorado Revised Statutes concerning limitations on payday lenders, and, in connection therewith, reducing allowable charges …

Yesterday, the court reversed course in the lawsuit filed by two industry trade groups challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule).  On its own initiative, the Texas federal district court granted a stay of the Payday Rule’s August 19, 2019 compliance date and continued in force its stay of the lawsuit. …