Small Dollar Lending Regulation in 2019

Hudson Cook, LLP

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 judicial stays and additional rulemaking, the compliance dates for this final rule continue to be pushed back—potentially to the point where the rule may never come to pass. However, small dollar lenders face legal challenges in their businesses outside potential CFPB regulations. This survey reviews updates in the small dollar lending space over the past year, including federal rulemaking, federal and state enforcement actions, significant state court decisions, and state legislation...

Originally published in The Business Lawyer; Vol. 75, Spring 2020.

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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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