A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take a closer look at the Proposed Rule and its implications for consumer lending generally. Comments on the Proposed Rule are due by September 14, 2016. The CFPB simultaneously issued a Request for Information (“RFI”) on other potentially high-risk loan products and practices not specifically covered by the Proposed Rule. Comments on the RFI are due by October 14, 2016.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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