An In Depth Analysis of CFPB’s Small Dollar Final Rule and Its Impact on Bank and Non-Bank Lenders

On July 7, 2020, the Consumer Financial Protection Bureau (CFPB) issued its final rule, the 2017 Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (Small Dollar Rule), which rescinded the ability to repay and underwriting provisions. The final rule does not, however, rescind or alter the payment provisions in the Small Dollar Rule, and the CFPB indicated that it would be moving forward with those provisions.

This webinar will provide an in-depth analysis of the payment provisions and the requirements for bank and non-bank lenders offering covered products. Specifically, we will discuss the compliance and operational considerations for processing consumer payments on covered loans. We will also discuss the impact of the recent federal inter-agency guidance for depository institutions offering small dollar loans and Madden fixes from the FDIC and OCC on the broader consumer finance marketplace.