More Scrutiny For Short-Term, Small-Dollar Loans

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On June 17, the U.S. Department of Defense issued advance notice of proposed rulemaking (ANPR) related to installment loans used by members of the armed forces and their families.

The rule, which would revise 32 C.F.R. Part 232, comes in the wake of the April 2013 proposed guidance on deposit advance products from the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, and the Consumer Financial Protection Bureau’s April 2013 white paper on payday loans and deposit advance products.

Originally Published in Law360, New York - July 08, 2013.

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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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