We. Just Exactly What’s Covered? . . . A lot more than You Believe.
Over per year after announcing its intend to reconsider its rule that is final onPayday, car Title, and Certain High-Cost Installment Loans” (the “Rule”), the buyer Financial Protection Bureau (the “CFPB”) formally posted into the Federal enter two notices of proposed rulemaking (collectively, the “NPRMs”) that rescind the Rule’s so-called “Mandatory Underwriting conditions” and extend the conformity due date for all those conditions by 15 months. Although the NPRMs leave unchanged the Rule’s byzantine re re payment limitations and notice provisions (the “Payment Provisions”), rescission for the Mandatory Underwriting Provisions nevertheless represents a substantive enhancement to an administrative rule poised to decimate an otherwise legal industry. (1)
