CFPB Proposes Framework For Payday, Title along with other Installment Loans

CFPB Proposes Framework For Payday, Title along with other Installment Loans

On June 2, 2016, the customer Financial Protection Bureau (the “CFPB” or perhaps the “Bureau”) released a 1,340-page notice of proposed Rulemaking on short-term lending (the “Proposal”)[1]. Our initial, high-level findings regarding the Proposal, which we continue steadily to evaluate, are set forth below.

The Proposal, among other items, may be the very first time the CFPB has utilized its authority to avoid unjust, misleading or abusive functions or techniques (“UDAAP”) being a basis for rulemaking. Even though it happens to be characterized being a loan that is”payday rule, as talked about more completely below, the Proposal would use throughout the short-term customer financing industry, including pay day loans, car name loans, deposit advance items and particular “high-cost” installment loans and open-end loans. Additionally would affect “lenders” – bank, non-bank, and market alike – that make “covered” loans for individual household or family purposes.