CFPB Update: Payday, Vehicle Title, & Installment Lending Rule
Published: Mon, 07/08/19
The CFPB has issued an update to their, "PAYDAY, VEHICLE TITLE, AND HIGH-COST INSTALLMENT LENDING RULE:
PAYMENT-RELATED REQUIREMENTS - SMALL ENTITY COMPLIANCE GUIDE
TABLE OF CONTENTS [Link to the PDF on our Blog: https://geni.us/CFPBupdate ]
Introduction
1. Scope and focus of this guide
2. A brief summary of Payday Lending Rule’s payment-related requirements, effective date, and the compliance date
3. Use of examples in this guide
4. Additional implementation resources
Covered loans
1. Covered short-term loans
2. Covered longer-term balloon-payment loans
3. Covered longer-term loans
4. Exclusions from coverage
5. Conditional exemptions
Lenders and service providers under the Payday Lending Rule
1. Lenders
2. Service providers.
4. Prohibited payment transfer attempts
1. Payment transfers
2. Conditional exclusion for certain transfers made by an account-holding institution
3. Exception for additional payment transfers authorized by the consumer in a new and specific authorization
4. Single immediate payment transfers at the consumer’s request
SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE: PAYMENT-RELATED REQUIREMENTS
Prohibition on evasion
Disclosure of payment transfer attempts
General form and delivery requirements for notices
1. First payment withdrawal notices
2. Unusual payment withdrawal notices
3. Consumer rights notices
4. Electronic short notices.Compliance program and record retention
1. Compliance program
2. Record retention
3. Prohibition on evasion
Again, here's a link to the full PDF update from the CFPB
https://geni.us/CFPBupdate
Jer - Trihouse Trihouseconsulting@gmail.com