CFPB Issues Final Rule for Payday & Vehicle Title Loans

On June 7, 2019, the CFPB issued a final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the previously issued 2017 final rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans. Compliance with the provisions of the 2017 rule is now delayed by 15 months, to November 19, 2020, so that the CFPB has sufficient time to re-evaluate this rule based on their proposal to reconsider the rule a few months ago. The Bureau is also making certain corrections to address several clerical and non-substantive errors it has identified in other aspects of the Rule. 

Information about this new final rule (and the delay of the implemntation of the 2017 rule) can be found here.

Promptly Investigating Under Regulation E

Promptly Investigating Under Regulation E

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