CFPB Updates Payday Lending Rule Small Entity Compliance Guide

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The CFPB recently updated its small entity compliance guide entitled “Payday, Vehicle Title, and High-Cost Installment Lending Rule: Payment-Related Requirements” to incorporate the changes made by recent final rulemaking, which delayed certain Payday Lending Rule requirements from going into effect and made various technical corrections.  WBK previously addressed this recent final rule here.

Generally, the revised guide addresses such updates related to the Payday Lending Rule, including the delay of the mandatory underwriting provisions’ compliance date (originally set for August 19, 2019, and currently set for November 19, 2020), the court-ordered stay on the rule’s compliance date, and the CFPB’s notice of proposed rulemaking to reconsider the mandatory underwriting provisions of the Payday Lending Rule.  The revisions also make deletions to the guide regarding proposed technical corrections that were adopted in the recent final rule.

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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