On June 2, 2016, the Consumer Financial Protection Bureau (CFPB) released a long-anticipated proposal pursuant to its authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act to regulate the provision and collection of certain short-term, small-dollar credit products, including payday and vehicle title loans, as well as certain longer-term high-rate installment and open-end loans. The proposal follows an outline of the bureau’s rulemaking plans floated in March 2015 as part of the consultation process prescribed in the Small Business Regulatory Enforcement Fairness Act (“SBREFA Outline”).
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