On February 6, 2019, the CFPB issued a notice of proposed rulemaking to rescind the mandatory underwriting provisions of the Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule and to delay the compliance date of this section of the rule, but left intact the payment provisions of the rule. The compliance date for the payment provisions is August 19, 2019. This webinar will break down the components of the payment provisions and what will be required under the new rule when processing consumer payments by both bank and non-bank lenders that offer covered products. This will be the second in a series of presentations to cover this topic and will focus on the returned payment obligations under the rule.
Specifically, we will cover what it means to have two consecutive returned payments under the CFPB’s new rule and some of the pitfalls involved with determining what constitutes a returned payment. Additionally, we will provide an overview for obtaining consent to obtain subsequent payments after two consecutive returned payments, including the timing and information required to obtain consent from the consumer.