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The Payday Lending Rule's general compliance date was supposed to be August 19, 2019. That compliance date, however, is currently stayed (delayed) under an order in a federal court case challenging the CFPB's legitimacy. As a result, lenders have no obligation to comply with the Rule until the court-ordered stay is lifted.
The parties to the federal court case are supposed to provide a joint status report to the judge in December. They and the judge could agree – at that time or sooner -- to have the stay lifted, making the rule effective on a mutually acceptable date (except for the underwriting requirements, which won't be effective until at least November 2020, and may be eliminated).
Is your bank ready? Have you figured out whether you make loans that will be subject to the rule? Will your bank qualify for an important exemption from the Rule's requirements?
In this one-hour presentation, you will --
- get a quick and easy way to determine whether loans your bank makes will be subject to the rule
- learn how to determine whether your bank qualifies for an exemption
- get the latest news on the rule's compliance date
In addition to those important topics discussed in our presentation, you'll also get written materials with information on what your institution needs to do if the stay is lifted. It covers
- The scope of loans covered by the rule
- Exemptions from coverage
- The role of "leveraged payment mechanisms"
- Alternative loans
- Credit union small loans
- Accommodation loans
- Unfair and abusive practices
- Permitted and prohibited methods for obtaining payments
- Borrower authorizations for payments
- Required disclosures related to payment authorizations
- Required notices of payment attempts
- Recordkeeping requirements
- Severability of requirements
- … and more
WHO SHOULD ATTEND:
Compliance officers, audit personnel, consumer lenders, lending management
The Payday Lending Rule
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