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 CFPB, the Federal Trade Commission (“FTC”), and various states continued to take action to curtail certain practices. While several courts looked at compliance matters involving small-dollar lenders, the U.S. Supreme Court issued an important administrative law decision that involved a small-dollar lender. This survey addresses compliance issues related to the small-dollar lending industry, including federal rulemaking, federal and state enforcement actions, significant court decisions, and state legislation.

Originally published in Spring 2022 issue of The Business Lawyer of the ABA Business Law Section.