The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and payment restrictions on certain covered loans. Be sure to review our previous blog post “CFPB Releases Long Awaited Small Dollar Rule: 5 Things You Need … Continue Reading
After months of speculation, the Consumer Financial Protection Bureau (CFPB) released a final small-dollar loan rule on October 5. If the final rule takes effect, lenders will be required, among other things, to determine whether consumers have the ability to repay (ATR) their loans, prior to issuing certain short-term small dollar, payday, and auto title … Continue Reading
In a recent case under the Telephone Consumer Protection Act (TCPA), the U.S. Court of Appeals for the Second Circuit held that the TCPA does not permit a consumer to revoke prior consent to be contacted by telephone when that consent was provided, “not gratuitously, but as part of a bargained-for consideration” in a contract. … Continue Reading
The Consumer Financial Protection Bureau (CFPB) issued its long-anticipated final rule on pre-dispute arbitration agreements on July 10. Clocking in at 775 pages, the final rule prohibits consumer financial services providers from including terms in arbitration agreements that limit a consumer’s ability to join or initiate a class action. While the rule falls short of … Continue Reading
Should a full-service consumer finance company be subject to federal debt collection law when it attempts to collect upon debt it purchased? Attorneys general from Maryland, the District of Columbia, California, New York, and more than two dozen other states have urged the Supreme Court to adopt a startling new interpretation of federal law and … Continue Reading
