The CFPB’s Payday/Auto Title/High-Rate Installment Loan Rule: A Look at the Uncertain Road Ahead
After we recap the 2017 final rule and its implications for industry, we discuss the CFPB’s actions to eliminate its ability-to-repay provisions but keep its payment provisions, possible use of the Congressional Review Act to restore the entire 2017 rule, status of the Texas litigation challenging the 2017 rule, potential impact of the 2020 presidential election, and our thoughts on preparing for the advent of the payment provisions.
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