Just in time for the holidays, the CFPB released its Fall 2015 rulemaking agenda on Friday, November 20. The agenda does not include any major surprises, but it does slightly revise the projected timeline for several highly anticipated rulemaking activities. Here are the highlights to consider between doses of turkey, football, and family.
..Payday and other short-term, small-dollar loans. The CFPB expects to publish a notice of proposed rulemaking (NPR) covering payday, deposit advance, and similar short-term, small-dollar loans in February 2016. The CFPB convened a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel in April 2015 to solicit input for the coming NPR, but it has yet to make public the report of the panel’s findings. Based on the CFPB’s comments on the topic to date, we anticipate the NPR would, among other things, require lenders to make a good faith determination of borrowers’ ability to repay certain short-term, small-dollar loans, and could limit the allowable frequency and total number of refinancings, or “roll overs,” with respect to such loans.
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