The Payday Lending Rule's general compliance date was supposed to be August 19, 2019. That date, however, is currently stayed (delayed) under an order in a federal court case challenging the CFPB's legitimacy and the validity of the Rule. As a result, lenders have no obligation to comply with the Rule until the court-ordered stay is lifted.
Earlier this year, the Supreme Court cleared up the legal status of the CFPB when it ruled that the Bureau’s management structure was unconstitutional because the director could only be dismissed by the president for cause, but ordered that the language of the law be changed to provide for dismissal at the will of the president. That hasn’t satisfied the plaintiff in the lawsuit filed in the federal court in Texas. We’ll discuss the plaintiff’s stance and any developments that may change the status of the Rule.
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 and the rule becomes effective. 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
- 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