Consumer Finance Monitor Podcast Episode: Should Written Contracts be Eliminated for Small Dollar Transactions? With David Hoffman, University of Pennsylvania Carey Law School
Welcome to the Payday and Small-Dollar Lending chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Regulators may take additional regulatory and enforcement action...more
A Nevada federal district court has stayed an action filed by the CFPB to enforce a civil investigative demand (CID) issued to a small-dollar lender pending the U.S. Supreme Court’s decision in Community Financial Services...more
In a comment letter sent last week to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra, a key financial industry trade group raised concerns that a recent edition of the CFPB’s Supervisory Highlights did not...more
Nebraska Governor, Jim Pillen, signed into law Legislative Bill 92 on June 6, 2023, which amended the Nebraska Installment Loan Act (the “Act”) effective June 7, 2023 (the “Effective Date”). As amended, the licensing...more
On July 26, 2023, the Consumer Financial Protection Bureau (“CFPB”) published its periodic Supervisory Highlights, summer edition. These most recent Supervisory Highlights shed light on a range of unfair, deceptive, and...more
The CFPB recently denied a lender’s request to set aside or modify a civil investigative demand (CID) issued in January related to its short-term and small-dollar lending practices. The lender’s redacted petition asserted...more
In this article, we share a timeline of our monthly "bites" for 2022 applicable to small-dollar lending. So, what happened in 2022?...more
During the past year, small-dollar lenders learned the fate of the Consumer Financial Protection Bureau’s (“CFPB”) final rulemaking addressing payday, vehicle title, and certain high-cost installment loans. In addition, the...more
Beginning next year, New Mexico will join a handful of other states (including, among others, California, Illinois, and Colorado) setting stringent interest rate caps on consumer loans. House Bill 132, which Gov. Michelle...more
[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more
Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more
Hawaii recently enacted significant changes to its small-dollar lending law that repeals existing Hawaii law on deferred deposits and creates a new regime for installment loans. Although H.B. 1192 took effect on July 1, the...more
Biden Administration Extends Student Loan Pause Until January 31, 2022 - "The Department believes this additional time and a definitive end date will allow borrowers to plan for the resumption of payments and reduce the...more
[co-author: Hurshell K. Brown - Beyond Finance, LLC] INTRODUCTION - Small-dollar lenders waited through most of 2020 for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rulemaking addressing payday, vehicle...more
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. In this month's article, we share our top "bites" covered during...more
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
How Virginia’s 2020 Fairness in Lending Act Reforms Small-Dollar Loans - "The law closes regulatory loopholes, caps interest rates, and provides lessons for other states." Why this is important: Earlier this year, the...more
Nothing is scarier than 2020! But Bradley has you covered with a treat. Here are a list of “Things That Go Bump in the Night: Top 10 Considerations to Watch Out for in the Small Dollar Lending Industry.” Wishing you a...more
In July 2020, the Consumer Financial Protection Bureau ("Bureau") at long last finalized the Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans ("Small Dollar Rule" or "Rule"). The Rule, originally...more
On August 28, 2020, the industry trade groups challenging the CFPB’s final Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans (the Rule) filed their Amended Complaint in accordance with the briefing...more
A recently-released Federal Reserve Board article, “The Cost Structure of Consumer Finance Companies and Its Implications for Interest Rates: Evidence from the Federal Reserve Board’s 2015 Survey of Finance Companies,”...more
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
On July 7, the CFPB issued its long-awaited final rule (the 2020 Final Rule) amending the regulations that govern payday loans, vehicle title loans and certain high-cost installment loans. As expected, the CFPB revoked the...more
The Consumer Financial Protection Bureau (CFPB) issued a final rule on July 7, 2020 rescinding the mandatory ability to repay underwriting provisions on small dollar loans that it had previously announced under 12 C.F.R. §...more