• CFPB To Consider Rules Restricting Certain Payday, Deposit Advance, Vehicle Title and Other Short-Term Lending: CFPB Proposal Would Require Lenders To Assess Customers’ Ability To Repay, Impose Cooling-Off Periods for Consecutive Loans, and Require Disclosures and Limits on Repayment Through Customer Accounts
  • May 8, 2015 | Authors: Darrell S. Cafasso; H. Rodgin Cohen; Mitchell S. Eitel; Robert J. Giuffra; Sharon L. Nelles
  • Law Firm: Sullivan & Cromwell LLP - New York Office
  • On March 26, 2015, the Consumer Financial Protection Bureau (the “CFPB” or the “Bureau”) announced that it will be considering rules imposing significant structural limitations and other requirements on payday and similar loans: (1) short-term (45 days or less) loans to consumers; and (2) longer-term (more than 45 days) high-interest rate personal loans (more than 36% measured by an “all in” annual percentage rate (APR) that is more inclusive than the Truth in Lending Act APR) where a lender has the right to collect from the customer’s paycheck or bank account, or where a non-purchase money loan is secured by the customer’s vehicle.