On June 2, 2016, the customer Financial Protection Bureau (the «CFPB» or the «Bureau») released a 1,340-page Notice of Proposed Rulemaking on short-term financing (the «Proposal»)[1]. Our initial, high-level findings in the Proposal, which we continue steadily to evaluate, are established below.
The Proposal, among other items, may be the time that is first CFPB has utilized its authority to stop unjust, misleading or abusive functions or techniques («UDAAP») as a basis for rulemaking. Though it is characterized as a «payday loan» rule, as talked about more completely below, the Proposal would use throughout the short-term customer financing industry, including payday advances, car title loans, deposit advance services and products and specific «high-cost» installment loans and open-end loans.