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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…

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…

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…

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…

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…

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. …

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…

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…