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Financial Services Law Insights and Observations

CFPB plans to reconsider payday rule

Agency Rule-Making & Guidance CFPB Succession CFPB Payday Lending

Agency Rule-Making & Guidance

On January 16, the CFPB announced plans to reconsider its final rule addressing payday loans, vehicle titles loans, and certain other extensions of credit (previously covered in a Buckley Sandler Special Alert) by engaging in a rulemaking process. While the announcement was made on the effective date of the final rule, most provisions do not require compliance until August 19, 2019. However, the deadline for submitting a preliminary approval to become a registered information system is April 16, 2018. The Bureau noted that it will consider waiver requests from potential applicants.

Notably, this marks the second recent announcement in which the agency refers to itself as “the Bureau of Consumer Financial Protection,” instead of the more-commonly used “Consumer Financial Protection Bureau.” Both titles are used in the text of the Dodd-Frank Act, though the sections of the Dodd-Frank Act authorizing creation of the CFPB used the “Bureau of Consumer Financial Protection” naming convention.  The agency also previously updated its mission statement located at the bottom of each release.

For more InfoBytes coverage on the latest CFPB changes, click here.