NPR reported last week that the Trump Administration is planning to end the current prohibition under the Military Lending Act (“MLA”) against creditors offering service members GAP insurance in connection with credit intended to finance the purchase of motor vehicles. Current interpretive guidance concerning the Department of Defense’s regulations implementing the MLA prohibits creditors from
Vehicle Loans
New York City adopts new requirements for used car dealers
By Wendy Angus-Anderson on
Posted in State CFS Monitor, Vehicle Loans
The New York City Department of Consumer Affairs (DCA) has adopted new rules for used car dealers, requiring all licensed dealers to make additional disclosures to consumers and creating a new consumer bill of rights for the industry. The new rules went into effect on June 24, 2018.
Under the new rules, dealers must provide…
Proposed bill would significantly expand MLA disclosure requirements
We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to covered members of the armed forces and their families. The text of H.R. 2697 is now available.
Titled the “Transparency in Military…
CFPB Consumer Advisory Board to meet on June 18
By Barbara S. Mishkin on
Posted in Payday Lending, Vehicle Loans
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…
Report from SBREFA Panel on Payday, Title and Installment Loans
By Mark J. Furletti on
Posted in Payday Lending, Vehicle Loans
Yesterday, I had the opportunity to participate as an advisor to a small entity representative (“SER”) at the small business review panel on payday, title and installment loans. (Jeremy Rosenblum has four posts—here, here, here and here—that analyze the rules being reviewed in detail.) The meeting was held in the Treasury…
The CFPB’s contemplated payday/title/high-cost lending proposals: our thoughts on collection practice limits
By Jeremy T. Rosenblum on
Posted in Payday Lending, Vehicle Loans
This is the last of a series of blog posts in which we share our reactions to the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s proposed limits on payment collection practices. (Our previous blog posts have looked…
Some issues for “longer-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals
By Jeremy T. Rosenblum on
Posted in Payday Lending, Vehicle Loans
In this blog post, we share our thoughts on the 36% “all-in” rate trigger and restrictions for loans considered to be “longer-term” under the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). (Our previous blog posts have looked at the CFPB’s grounds for the proposals, how the proposals will…
Some issues for “short-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals
By Jeremy T. Rosenblum on
Posted in Payday Lending, Vehicle Loans
In this blog post, we share our thoughts on how the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”) will impact “short-term” Covered Loans and the flaws we see in the CFPB’s ability to repay analysis. (Our last blog post looked at the CFPB’s grounds for the proposals.)
Impact. …
The CFPB’s contemplated payday/title/high-cost lending proposals: our initial reactions
By Jeremy T. Rosenblum on
Posted in Payday Lending, Vehicle Loans
Last Friday, we posted a summary of the contemplated CFPB proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s grounds for the proposals. Over the next few days, we will be publishing several additional blog posts to share our reactions to…
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…