Consumer Finance Monitor Podcast Episode: Should Written Contracts be Eliminated for Small Dollar Transactions? With David Hoffman, University of Pennsylvania Carey Law School
Welcome to the Payday and Small-Dollar Lending chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Regulators may take additional regulatory and enforcement action...more
In a comment letter sent last week to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra, a key financial industry trade group raised concerns that a recent edition of the CFPB’s Supervisory Highlights did not...more
Nebraska Governor, Jim Pillen, signed into law Legislative Bill 92 on June 6, 2023, which amended the Nebraska Installment Loan Act (the “Act”) effective June 7, 2023 (the “Effective Date”). As amended, the licensing...more
On July 26, 2023, the Consumer Financial Protection Bureau (“CFPB”) published its periodic Supervisory Highlights, summer edition. These most recent Supervisory Highlights shed light on a range of unfair, deceptive, and...more
The CFPB recently denied a lender’s request to set aside or modify a civil investigative demand (CID) issued in January related to its short-term and small-dollar lending practices. The lender’s redacted petition asserted...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
Beginning next year, New Mexico will join a handful of other states (including, among others, California, Illinois, and Colorado) setting stringent interest rate caps on consumer loans. House Bill 132, which Gov. Michelle...more
[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more
Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more
Hawaii recently enacted significant changes to its small-dollar lending law that repeals existing Hawaii law on deferred deposits and creates a new regime for installment loans. Although H.B. 1192 took effect on July 1, the...more
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. In this month's article, we share our top "bites" covered during...more
How Virginia’s 2020 Fairness in Lending Act Reforms Small-Dollar Loans - "The law closes regulatory loopholes, caps interest rates, and provides lessons for other states." Why this is important: Earlier this year, the...more
On August 28, 2020, the industry trade groups challenging the CFPB’s final Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans (the Rule) filed their Amended Complaint in accordance with the briefing...more
A recently-released Federal Reserve Board article, “The Cost Structure of Consumer Finance Companies and Its Implications for Interest Rates: Evidence from the Federal Reserve Board’s 2015 Survey of Finance Companies,”...more
On July 7, the CFPB issued its long-awaited final rule (the 2020 Final Rule) amending the regulations that govern payday loans, vehicle title loans and certain high-cost installment loans. As expected, the CFPB revoked the...more
The Consumer Financial Protection Bureau (CFPB) issued a final rule on July 7, 2020 rescinding the mandatory ability to repay underwriting provisions on small dollar loans that it had previously announced under 12 C.F.R. §...more
On May 20, the OCC, the FDIC, the Federal Reserve Board and the National Credit Union Administration issued “Interagency Lending Principles for Offering Responsible Small-Dollar Loans.” ...more
The CFPB, OCC, FDIC, Federal Reserve, and NCUA have issued a joint statement “to specifically encourage” banks, savings associations, and credit unions “to offer responsible small-dollar loans to both consumers and small...more
Bank partnerships allow banks to offer loans to consumers and businesses by leveraging the resources of non-bank entities. The relationships between banks and their non-bank entity partners have existed for many years. In the...more
Consumer advocates have heavily criticized Director Kraninger and former Acting Director Mick Mulvaney for taking a much less aggressive attitude towards enforcement than former Director Cordray. ...more