CFPB’s Exam Findings Related to Short-Term Small-Dollar Lending in Summer 2020 Supervisory Highlights
We review the CFPB’s findings that lenders engaged in deceptive practices and violated Regulation Z advertising requirements based on the following conduct and discuss the findings’ compliance implications: false representations about consumers’ ability to apply for loans online and the absence of credit checks; false threats in collection letters about lien placement, asset seizure, and charging late fees; and advertising “free loans” without including the additional information required when using a “triggering term” or where the loan was free only if prepaid.
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