On April 3, 2023, the Consumer Financial Protection Bureau issued a policy statement on "abusive" practices. While this is the second time the CFPB has issued a policy statement on abusiveness, the significance of this policy...more
On March 2, 2023, the CFPB released a report entitled "Consumer use of Buy Now, Pay Later: Insights from the CFPB Making Ends Meet Survey," examining Buy Now, Pay Later ("BNPL") products. BNPL products typically allow...more
Remember that magazine you subscribed to years ago that comes once a month and usually winds up in the recycling bin? You probably didn't think you were subscribing to the magazine for the rest of your natural life but here...more
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...more
In September 2021, the FTC approved technical changes to five regulations implementing the Fair Credit Reporting Act.
Under the Dodd-Frank Act, the CFPB may not exercise any rulemaking, supervisory, enforcement or any...more
[co-author: Hurshell K. Brown - Beyond Finance, LLC]
INTRODUCTION -
Small-dollar lenders waited through most of 2020 for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rulemaking addressing payday, vehicle...more
In July 2020, the Consumer Financial Protection Bureau ("Bureau") at long last finalized the Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans ("Small Dollar Rule" or "Rule"). The Rule, originally...more
In June of this year, the United States Supreme Court held that an employer who fires an employee for being gay or transgender violates the Civil Rights Act of 1964 ("Title VII"). Title VII prohibits employers from refusing...more
7/31/2020
/ Bostock v Clayton County Georgia ,
Consumer Financial Protection Bureau (CFPB) ,
Creditors ,
ECOA ,
Equal Access to Credit ,
Gender Identity ,
Hiring & Firing ,
LGBTQ ,
Request For Information ,
Risk Assessment ,
Risk Mitigation ,
SCOTUS ,
Sex Discrimination ,
Sexual Orientation ,
Sexual Orientation Discrimination ,
Title VII ,
Transgender ,
Underwriting
One year ago, small dollar lenders were operating under the specter of looming compliance dates for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rule concerning small dollar lending. One year later, through...more
5/13/2020
/ CA Supreme Court ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Regulatory Agencies ,
GA Supreme Court ,
Risk Assessment ,
Risk Mitigation ,
Small Dollar Lenders ,
State Attorneys General ,
State Legislatures ,
State Regulators
Motor vehicle financing can be full of compliance minefields. Defaults and repossessions provide more than their fair share of potential mines. However, there are some steps you can take to try to avoid some key issues that...more
11/26/2019
/ Automotive Loans ,
Car Dealerships ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Financing ,
Default ,
Fees ,
Information Sharing ,
Personal Property ,
Repossess ,
Risk Mitigation ,
Strict Compliance ,
Written Agreements
Prioritizing compliance with federal and state law may be the last item on your never ending to-do list. Most days, you have bigger fish to fry - you want to increase sales and decrease overhead. However, a small investment...more
6/19/2019
/ Automotive Loans ,
Car Dealerships ,
Civil Monetary Penalty ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
EFTA ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Federal Trade Commission (FTC) ,
Financial Regulatory Agencies ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Restitution ,
Risk Assessment ,
Risk Mitigation ,
Settlement ,
State Regulators ,
Truth in Lending Act (TILA) ,
Unfair or Deceptive Trade Practices
During the past year, many small dollar lenders operated under looming rulemaking from the Bureau of Consumer Financial Protection (“CFPB”), which threatened elimination of their businesses. This survey reviews small dollar...more