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 proposals under consideration on the same topic. Comments on the proposed rule are due on Sept. 14, 2016.
Although the rulemaking has been characterized as the “payday loan rule,” it is sweeping in terms of the products covered and the limitations it would impose on the short-term consumer lending industry generally. Notably, this is the CFPB’s first proposed rule based on the agency’s power to restrict “unfair, deceptive or abusive” acts or practices (UDAAP).
Originally published in Law360 on June 14, 2016.
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