The CFPB recently issued its small entity compliance guide for the Payday Lending Rule that specifically focuses on the Rule’s payment-related requirements.
The Payday Lending Rule, which covers payday, vehicle title and high cost installment loans, went into effect January 16, 2018, although the August 19, 2019, compliance date of the rule was stayed by a federal judge. As a result, lenders have no obligation to comply with the Rule until the court-ordered stay is lifted. The CFPB also recently announced a notice of proposed rulemaking, proposing to delay the Rule’s compliance date to November 19, 2020, and rescind certain underwriting provisions of the Payday Lending Rule. Although the guide focuses on the payment provisions of the Payday Lending Rule, it also summarizes the Rule’s general (i.e., coverage) provisions as well as its record retention and compliance program requirements as they relate to the payment provisions.