As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take a closer look at the Proposed Rule and its implications for consumer lending generally. Comments on the Proposed Rule are due by September 14, 2016. The CFPB simultaneously issued a Request for Information (“RFI”) on other potentially high-risk loan products and practices not specifically covered by the Proposed Rule. Comments on the RFI are due by October 14, 2016.
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