On February 20, 2019, the CFPB released a Small Entity Compliance Guide (“Guide”) summarizing the requirements of the Payday, Vehicle Title, and High-Cost Installment Lending Rule (“Payday Lending Rule”).
As previously reported, here, on February 6, 2019, the CFPB had issued a proposed rule seeking, among other things, to rescind the ability to repay requirement and related mandatory underwriting provisions of the Payday Lending Rule (“NPRM”).
According to the Guide, the CFPB intends to update the Guide at a later date, likely once Payday Lending Rules are finalized following the NPRM, to assist industry with the implementation of the Payday Lending Rule’s underwriting provisions.
If you have any questions regarding the Payday Lending Rule or the NPRM, please reach out to Solomon Maman.
Author
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Solomon has nearly two decades of experience representing financial institutions, real estate investors and privately owned business entities. Solomon concentrates his practice in the areas of banking, consumer financial services, real estate, business law and related litigation and appellate practice.
