What You Need to Know About the CFPB's Short-Term, Small-Dollar Lending Examination Procedures


The Consumer Financial Protection Bureau (CFPB) recently updated its Supervision and Examination Manual to include Short-Term, Small-Dollar Examination Procedures. These procedures apply to what is commonly known as payday lending and are comprised of examination modules covering the entire lifecycle of a payday loan, including Marketing; Application and Origination; Payment Processing and Sustained Use; Collections, Accounts in Default, and Consumer Reporting; and Third-Party Relationships.

Our panel of experienced financial services regulation and compliance professionals discuss the CFPB's Short-Term, Small-Dollar Examination Procedures. The panel provides an overview of the procedures and discuss what to expect from the CFPB's examinations of payday lenders.


Timothy R. McTaggart, partner, Pepper Hamilton LLP, and former Delaware bank commissioner


Richard P. Eckman, partner and chairman of the Financial Services Practice Group, Pepper Hamilton LLP

John C. Soffronoff, Jr., president of compliance, ICS Risk Advisors (recently acquired by FIS) and former review examiner in the FDIC's New York regional office

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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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