News & Analysis as of

Consumer Financial Protection Bureau (CFPB) Ability-to-Repay Proposed Regulation

Manatt, Phelps & Phillips, LLP

CFPB Releases Proposed Regulation of Payday Loans

In a long anticipated move, the Consumer Financial Protection Bureau (CFPB) proposed a rule to regulate so-called "debt traps" by requiring lenders to take additional steps to ensure consumers have the ability to repay...more

McGuireWoods LLP

CFPB Proposes Rule on Small Dollar Lending

McGuireWoods LLP on

On June 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) released its proposed rule on small dollar lending during its scheduled field hearing in Kansas City, Missouri. The controversial proposed rule will affect...more

Morrison & Foerster LLP

Short-Term Lenders Face Costly Path To Compliance

On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more

BCLP

The CFPB Proposes Ambitious Payday Lending Regulations

BCLP on

On June 2, 2016, the CFPB released its long-awaited proposed regulations for payday loans, vehicle title and certain high-cost installment loans. Comments on the proposed rules must be received on or before September 14,...more

K&L Gates LLP

Payday Loans Under Attack: The CFPB's New Rule Could Dramatically Affect High-Cost, Short-Term Lending

K&L Gates LLP on

On June 2, 2016, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) proposed a new rule under its authority to supervise and regulate certain payday, auto title, and other high-cost installment loans (the “Proposed...more

Ballard Spahr LLP

CFPB issues proposed payday/auto title/high-rate installment loan rule

Ballard Spahr LLP on

As expected, the CFPB issued its proposed payday loan rule, in a release running 1,334 pages. The CFPB also issued a fact sheet summarizing the proposal. Once we complete our initial review of the proposal, we will issue a...more

Locke Lord LLP

Consumer Financial Protection Bureau (CFPB) Prepares Proposals to Add Repay Ability, Other Requirements to Small-Dollar Lending...

Locke Lord LLP on

How will the CFPB’s attempts to put an end to payday debt traps impact financial institutions and consumers? JS: If published as outlined, these proposals would impose all too familiar ability to repay requirements,...more

MoFo Reenforcement

The CFPB Outlines an Approach to So-Called “Debt Trap” Products

MoFo Reenforcement on

At a field hearing in Richmond, Virginia on March 26, the Consumer Financial Protection Bureau (CFPB) outlined the proposal it is considering to regulate payday lending. The proposal would cover short- and long-term payday...more

Ballard Spahr LLP

The CFPB’s contemplated payday/title/high-cost lending proposals: our thoughts on collection practice limits

Ballard Spahr LLP on

This is the last of a series of blog posts in which we share our reactions to the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our...more

Ballard Spahr LLP

Some issues for “longer-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals

Ballard Spahr LLP on

In this blog post, we share our thoughts on the 36% “all-in” rate trigger and restrictions for loans considered to be “longer-term” under the CFPB’s contemplated proposals taking aim at payday (and other small-dollar,...more

Baker Donelson

Proposed Data Reporting Rule Issued

Baker Donelson on

If you are looking for some light reading these last few weeks of summer, you might want to take a look at the recently released proposed rule regarding changes to the Home Mortgage Disclosure Act (HMDA) also known as...more

Orrick - Finance 20/20

CFPB Proposed Clarifications on Qualified Mortgage Rules

Orrick - Finance 20/20 on

On April 19, the CFPB released proposed rule amendments to the ability to repay/qualified mortgage (QM) rules. The proposals address...more

Stinson - Corporate & Securities Law Blog

CFPB Begins To Fix Recently Adopted Rules

The CFPB has issued a proposed rule clarifying and making technical amendments to the 2013 Escrows Final Rule issued by the Bureau in January 2013. This is the first of the CFPB’s planned issuances to clarify and provide...more

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