CFPB Problems Amendments to Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule

CFPB Problems Amendments to Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule

REGULATORY ALERT

Dear Panels of Directors and Chief Executive Officers:

On July 22, 2020, the customer Financial Protection Bureau issued a rule that is finalstarts brand new screen) amending elements associated with the Payday, car Title, and Certain High-Cost Installment Loans Rule, 12 CFR component 1041 (CFPB Payday Rule). Although the CFPB Payday Rule became effective on January 16, 2018, the conformity times are currently stayed pursuant up to a court order issued due to pending litigation. 1 because of this, loan providers aren’t obliged to conform to the guideline before the stay that is court-ordered lifted.

The July 2020 amendment to your guideline rescinds the next:

  • Need for a loan provider to determine a borrower’s ability to settle before you make a loan that is covered
  • Underwriting requirements in making the ability-to-repay determination; and
  • Some recordkeeping and reporting requirements.

The CFPB Payday Rule’s provisions relating to cost withdrawal limitations, notice needs, and associated recordkeeping requirements for covered short-term loans, covered longer-term balloon repayment loans, and covered longer-term loans are not changed because of the July rule that is final. Continue reading “CFPB Problems Amendments to Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule”