On November 5, 2020, the CFPB named Driver Loan, LLC (“Driver Loan”) and its Chief Executive Officer as defendants in a two-count complaint filed in a Florida federal district court that alleges they engaged in deceptive acts and practices in violation of the Dodd-Frank Act’s UDAAP prohibition in connection with taking deposits from and making

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

In the aftermath of a statement from the CFPB and the four federal banking agencies encouraging small-dollar lending in response to the COVID-19 pandemic and guidance from the four federal banking agencies on “Interagency Lending Principles for Offering Responsible Small-Dollar Loans,” the CFPB has issued a “No-Action Letter (NAL) Template” for small-dollar loan

The Federal Reserve, OCC, FDIC, and NCUA have issued “Interagency Lending Principles for Offering Responsible Small-Dollar Loans.”  The agencies state that the principles are intended “to encourage supervised banks, savings associations, and credit unions to offer responsible small-dollar loans to customers for consumer and small business purposes.”

The issuance of the guidance follows

The CFPB, OCC, FDIC, Federal Reserve, and NCUA have issued a joint statement “to specifically encourage” banks, savings associations, and credit unions “to offer responsible small-dollar loans to both consumers and small businesses” in response to the COVID-19 outbreak.  The statement builds on the March 19 statement issued jointly by the OCC, FDIC, and Federal

This week, two House Financial Services Subcommittees will hold hearings.

Tomorrow afternoon at 2:00PM ET, the Consumer Protection and Financial Institutions Subcommittee will convene a hearing entitled, “Ending the Debt Traps in the Payday and Small Dollar Credit Industry.”

On Wednesday, May 1 at 10:00AM ET, the Oversight and Investigations subcommittee will convene a

Comptroller of the Currency Joseph Otting issued a statement today in support of the CFPB’s proposal that would rescind in their entirety the ability-to-repay (ATR) provisions in its final payday/auto title/high-rate installment loan rule.  (The CFPB has also proposed to delay the mandatory compliance date for the ATR provisions until November 19, 2020 but took

A group of 13 state attorneys general and the District of Columbia AG have sent a letter to the FDIC commenting on the agency’s request for information on small-dollar lending.  The RFI, published in November 2018, seeks input on “steps the FDIC could take to encourage FDIC-supervised institutions to offer responsible, prudently underwritten small-dollar

The FDIC has published a request for information (RFI) on small-dollar lending, including “steps the FDIC could take to encourage FDIC-supervised institutions to offer responsible, prudently underwritten small-dollar credit products that are economically viable and address the credit needs of bank customers.”  (The FDIC supervises state-chartered banks and savings institutions that are not Federal Reserve

With the August 19, 2019 compliance date for the CFPB’s small dollar lending rule drawing nearer, industry anxiety is growing as to the CFPB’s plans for delaying the compliance date and what changes will be proposed.  In this episode, we review what the rule’s ability to pay and repayment provisions would require and why those