CFPB Payday Lending Rule: Status and Prospects
The CFPB has issued highly-anticipated proposed revisions to its final payday/auto title/high-rate installment loan rule that would rescind its ability-to-repay (ATR) provisions in their entirety and delay by 15 months the August 19, 2019 compliance date for the ATR provisions. At the same time, the CFPB’s proposals would leave unchanged the rule’s troublesome payment provisions and continue to require compliance by August 19 with those provisions. Please join us for a discussion of what the CFPB has proposed and how its proposals are likely to fare.
• The CFPB’s basis for the proposals
• Possible political and legal challenges
• Preparing for compliance with the payment provisions
• How the industry should respond