On July 7, 2020, the Consumer Financial Protection Bureau issued its final rule in regard to so-called small dollar loans. The biggest change from the CFPB’s original iteration of the rule, the 2017 Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (the “Small Dollar Rule”) is the bureau’s decision to rescind 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 will be moving forward with those provisions.
This webinar will cover the following topics:
- An in-depth analysis of the Payment Provisions and the requirements for non-bank lenders offering covered products
- Compliance and operational considerations for processing consumer payments on covered loans
- The impact COVID-19, bank partnership modeling, and market-place-lending have had on the industry