Payday, Vehicle Title, And High-Cost Installment Lending Rule

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July 2020Payday, Vehicle Title, andHigh-Cost InstallmentLending RuleSmall Entity Compliance Guide

Version LogThe Bureau updates this guide on a periodic basis. Below is a version log noting the history ofthis document:DateVersionSum m ary of ChangesJuly 20203.0Updated to address the final rule released on July 7, 2020(Revocation Final Rule), including: Revisions to incorporate the Revocation Final Rule intothe introductory sections (Sections 1 and 1.1); Deletion of footnote discussing the delayed com pliancedate for the m andatory underw riting provisions (Section1.2.2); and Revisions to include the requirement that lenders m ustretain or be able to reproduce an im age of the loanagreem ent for each covered loan that the lenderoriginates (Section 6.2).Updated to note that this guide is a Com pliance Aid under theBureau’s Policy Statem ent on Com pliance Aids (Section 1).Updated to reflect m iscellaneous adm inistrative changes.June 20192.0Updated to address the delay of the m andatory underwritingprovisions and the technical corrections set forth in the final rulereleased on June 6, 2019 (Delay Final Rule), including: Revisions to the introduction to include the Delay FinalRule (Section 1); Revisions to account for the delayed com pliance date forthe m andatory underw riting provisions and the addition ofnew 12 CFR 1041.15 (Section 1.2.2);SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

Deletion of footnote regarding proposed technicalcorrections because those changes w ere adopted in theDelay Final Rule (Section 2.5.1); Revision of the Bureau’s w eb address to be included inConsum er Rights Notice and deletion of footnoteregarding proposed technical corrections because thosechanges w ere adopted in the Delay Final Rule (Section5.4); and Revision of footnote to account for the delayedcom pliance date for the m andatory underw ritingprovisions (Section 6.2).Updated to reflect m iscellaneous adm inistrative changes.February2019Original Version1.0SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

Table of contents1.2.Introduction .51.1Scope and focus of this guide. 61.2Brief summary of Payday Lending Rule’s payment-relatedrequirements, effective date, and compliance date . 71.3Use of examples in this guide . 91.4Additional implementation resources. 9Covered loans .102.1Covered short-term loans .112.2 Covered longer-term balloon-payment loans . 132.3 Covered longer-term loans . 152.4 Exclusions from coverage . 202.53.Conditional exemptions . 23Lenders and service providers under the Payday Lending Rule.293.1Lenders . 293.2 Service providers . 304.Prohibited payment transfer attempts .324.1Payment transfers . 334.2 Conditional exclusion for certain transfers made by an account-holdinginstitution. 354.3 Prohibition on making certain payment transfers . 364.4 Exception for additional payment transfers authorized by the consumerin a new and specific authorization. 39SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

4.5 Single immediate payment transfers at the consumer’s request . 434.6 Prohibition on evasion .445.Disclosure of payment transfer attempts .465.1General form and delivery requirements for notices. 475.2 First payment withdrawal notices . 505.3 Unusual payment withdrawal notices . 545.4 Consumer rights notices . 585.56.Electronic short notices . 60Compliance program and record retention .636.1Compliance program . 636.2 Record retention . 636.3 Prohibition on evasion . 65SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

1. IntroductionOn October 5, 2017, the Consumer Financial Protection Bureau (Bureau) issued a final rulegoverning certain personal loans with short-term or balloon-payment structures and certainadditional installment loan products (2017 Payday Lending Rule). On February 6, 2019, theBureau issued: (1) a notice of proposed rulemaking to reconsider the 2017 Payday LendingRule’s mandatory underwriting provisions; 1 and (2) a notice of proposed rulemaking to delaythe August 19, 2019 compliance date of the mandatory underwriting provisions. 2On June 6, 2019, the Bureau issued a final rule (Delay Final Rule) 3 finalizing the second of thesetwo proposals. The Delay Final Rule delayed the August 19, 2019 compliance date for the 2017Payday Lending Rule’s mandatory underwriting provisions to November 19, 2020 and madetechnical corrections to the 2017 Payday Lending Rule. On July 7, 2020, the Bureau issued afinal rule (Revocation Final Rule) to revoke certain provisions of the 2017 Payday Lending Rule.Effective ninety days after its publication in the Federal Register, the Revocation Final Rulerevokes the Rule’s mandatory underwriting provisions and amends other provisions of the 2017Payday Lending Rule that reference the mandatory underwriting provisions.This guide uses the term “Payday Lending Rule” or “Rule” to refer to the 2017 Payday LendingRule as amended by the Delay Final Rule and the Revocation Final Rule.18 4 Fed. Reg. 4252 (Feb. 1 4, 2019).28 4 Fed. Reg. 4298 (Feb. 1 4, 2019).38 4 Fed. Reg. 27907 (June 17, 2019).5SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

This guide meets the requirements of Section 212 of the Small Business Regulatory EnforcementFairness Act of 1996 with regard to the Payday Lending Rule.This guide is a Compliance Aid issued by the Consumer Financial Protection Bureau. TheBureau published a Policy Statement on Compliance Aids, available -aids/, that explains the Bureau’s approach to Compliance Aids.1.1Scope and focus of this guideThis guide focuses on the Payday Lending Rule. 4 Except when specifically needed to explain thePayday Lending Rule, this guide does not discuss other laws, regulations, or regulatory guidancethat may apply.Users of this guide should review the Payday Lending Rule as well as this guide. The PaydayLending Rule is available on the Bureau’s website at idance/payday-lending-rule.The content of this guide does not include any rules, bulletins, guidance, or other interpretationsissued or released after the date on the guide’s cover page.46T h e Rev ocation Final Rule, which revokes the m andatory underwriting prov isions, is effective ninety days after it ispu blished in the Federal Register. T he Delay Final Rule delays the com pliance date of m ost of t hese prov isionsu n til Nov ember 1 9, 2020. The revocation of the mandatory underwriting provisions will be effective before thecom pliance delay ends. Lenders are n ot r equired to com ply with the Payday Lending Rule’s m andatoryu n derwriting prov isions. T hus, this guide does not discuss the mandatory underwriting provisions.SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

1.2Brief summary of Payday LendingRule’s payment-relatedrequirements, effective date, andcompliance date1.2.1Brief summary of the Payday Lending Rule’spayment-related requirementsA “lender” is defined in the Payday Lending Rule as a person that regularly extends credit toconsumers primarily for personal, family, or household purposes. The Rule applies to lendersthat make “covered loans” as that term is defined in the Rule. Generally, covered loans include:1. Covered short-term loans that require repayment within 45 days of consummation oran advance. Such loans are covered loans regardless of the cost of credit;2. Covered longer-term loans that have certain types of balloon-payment structures.These loans are also covered loans regardless of the cost of credit; and3. Covered longer-term loans that have a cost of credit exceeding a 36 annual percentagerate (APR) and that have a leveraged payment mechanism giving the lender the rightto initiate transfers from the consumer’s account without further action by theconsumer. 5Certain accommodation loans and alternative loans that generally conform to the NationalCredit Union Administration’s (NCUA’s) requirements for the Payday Alternative Loan (PAL)program set forth in 12 CFR 701.21(c)(7)(iii) are exempted from being covered loans. Eightother types of loans are excluded from being covered loans. For example, perfected mortgage57A s discussed in Section 2.3, a leveraged payment m echanism does not include initiating a single im mediate paymentt r ansfer (i.e., a on e-tim e transfer initiated within on e business day after the consumer proffers a check or authorizesa n electronic transfer).SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

loans, purchase money security interest loans, credit card accounts, and certain overdraftservices and overdraft lines of credit are not covered loans.The Payday Lending Rule imposes two types of requirements regarding lenders’ repeatedattempts to withdraw payments from consumers’ accounts after prior attempts have failed dueto insufficient funds.First, where two consecutive withdrawal attempts have failed due to insufficient funds, the Ruleprohibits a lender from attempting another withdrawal from the same account unless the lenderobtains the consumer’s new and specific authorization to make further withdrawals from theaccount. This prohibition on further withdrawal attempts applies whether the two failedattempts are initiated through a single payment channel or different channels, such as theautomated clearinghouse (ACH) system or the check network. These requirements do not applyto a lender’s withdrawal attempts if the lender is the institution that holds the consumer’saccount and the lender meets certain conditions.Second, a lender is required to provide a written notice before its first attempt to withdrawpayment for a covered loan from a consumer’s account and before subsequent attempts thatdeviate from scheduled amounts or dates or that involve a different payment channel than theprior attempt. The Rule also requires a lender to provide a consumer rights notice if twoconsecutive attempts to withdraw payment have failed due to insufficient funds in a consumer’saccount. The Rule details the information that must be included in the notices and how they canbe provided, including permissible methods of electronic delivery. The Rule’s noticerequirements do not apply to a lender’s withdrawal attempts if the lender is the institution thatholds the consumer’s account and the lender meets certain conditionsA lender making a covered loan must develop and follow written policies and proceduresdesigned to ensure compliance with the Payday Lending Rule. Lenders must also retainevidence of compliance for 36 months. The Rule outlines the types and format of informationthat lenders must retain.1.2.2Effective date and compliance date of the PaydayLending RuleThe Payday Lending Rule became effective on January 16, 2018. However, the Rule’scompliance date for the payment-related requirements is August 19, 2019. Thus, by its terms,8SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

the Rule does not require lenders to comply with the Rule’s payment-related requirements untilAugust 19, 2019. See 12 CFR 1041.15. The compliance date, however, is currently stayedpursuant to a court order issued in Community Financial Services Association v. CFPB, No.1:18-cv-00295 (W.D. Tex. Nov. 6, 2018). As a result, lenders have no obligation to comply withthe Rule until the court-ordered stay is lifted.1.3Use of examples in this guideThis guide has examples to illustrate some portions of the Payday Lending Rule. The examplesdo not include all possible factual situations that could illustrate a particular provision, trigger aparticular obligation, or satisfy a particular requirement.1.4Additional implementation resourcesAdditional resources to help industry understand and comply with the Payday Lending Rule areavailable on the Bureau’s website at idance/payday-lending-rule. You may also sign up on this website for an emaildistribution list that the Bureau will use to announce additional resources as they becomeavailable.If you have a specific regulatory interpretation question about the Payday Lending Rule afterreviewing these resources, you can submit the question to the Bureau on its website athttp://reginquiries.consumerfinance.gov. You may also leave your question in a voicemail at202-435-7700.Bureau staff provides only informal responses to regulatory inquiries, and the responses do notconstitute official interpretations or legal advice. Bureau staff is not able to respond to specificinquiries within a particular requested timeframe. Actual response times will vary based on thenumber of questions Bureau staff is handling and the amount of research needed to respond to aspecific question.9SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

2. Covered loansThe Payday Lending Rule applies to “covered loans” made by a “lender,” as those terms aredefined in the Rule. This Section 2 discusses how to determine whether a loan is a “coveredloan.” Section 3 discusses who is a lender under the Payday Lending Rule.The Payday Lending Rule applies to three types of loans extended to a consumer for personal,family, or household purposes. The Rule and this guide collectively refer to these three types ofloans as “covered loans.” The criteria for each type of covered loan are discussed in more detail,below, but generally the three types of covered loans are:1. Covered short-term loans that require repayment within 45 days of consummation oran advance. Such loans are covered loans regardless of the cost of credit;2. Covered longer-term loans that have certain types of balloon-payment structures.These loans are also covered loans regardless of the cost of credit; and3. Covered longer-term loans that have a cost of credit exceeding a 36 annual percentagerate (APR) and that have a leveraged payment mechanism giving the lender the rightto initiate transfers from the consumer’s account without further action by theconsumer. 6Certain types of loans are excluded or exempted from the Payday Lending Rule.As outlined in Section 2.4, the Payday Lending Rule excludes eight categories of loans from thedefinition of covered loan, including perfected mortgage loans, purchase money security interestloans, credit card accounts, and certain overdraft services and overdraft lines of credit.As outlined in Section 2.5, the Payday Lending Rule exempts two categories of otherwisecovered loans:6A s discussed in Section 2.3, a leveraged payment m echanism does not include initiating a single im mediate paymentt r ansfer (i.e., a on e-tim e transfer initiated im mediately a fter t he consumer proffers a check or authorizes anelectronic transfer).10SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

1. Alternative loans, which are loans that generally conform to the NCUA’s requirementsfor the PAL program set forth in 12 CFR 701.21(c)(7)(iii), regardless of whether thelender is a federally insured credit union; and2. Accommodation loans, provided the lender together with its affiliates do not originatemore than 2500 covered loans in a calendar year and did not derive more than 10percent of their receipts from covered loans during the previous tax year.2.1Covered short-term loansA loan is a covered short-term loan if it meets all of the following:1. Is an extension of credit to a consumer (i.e., an individual or an individual’s agent ortrustee). Transactions that do not constitute credit are not subject to the PaydayLending Rule.2. Is extended primarily for personal, family, or household purposes. Lenders may relyon Regulation Z, 12 CFR 1026.3(a)and its related commentary, whenFor purposes of the Payday Lending Rule,determining the primary purpose ofopen-end credit is an extension of credit toa loan. Comment 1041.3(b)-2.an individual or an individual’s agent,3. Requires a consumer to repaysubstantially the entire amount ofthe loan within 45 days ofconsummation or to repaysubstantially the entire amount ofany advance within 45 days of theadvance, as applicable.For closed-end credit that providesfor a single advance, this criterion issatisfied if the consumer is requiredto repay a substantial majority of theloan within 45 days ofconsummation. For all other loans(i.e., open-end credit and closed-endcredit that provides for multipleadvances), this criterion is satisfied if11trustee, or representative that is open-endcredit as defined in Regulation Z, 12 CFR1 026.2(a)(20), but without regard to whetherthe credit is consumer credit underRegulation Z, is extended by a creditor asdefined in Regulation Z, is extended to aconsumer as defined in Regulation Z, orpermits a finance charge to be imposed fromtime to time on an outstanding balance asdefined in Regulation Z. 12 CFR1 041.2(a)(16); comment 1041.2(a)(16)-1. Forpurposes of the Rule, closed-end credit is anex tension of credit to an individual or anindividual’s agent, trustee, or representativethat is not open-end credit. 12 CFR1 041.2(a)(3); comment 1041.2(a)(3)-1.SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

the consumer is required to repay a substantial majority of any advance within 45days of the advance.The determination of whether a loan is substantially repayable within 45 daysdepends on the facts and circumstances, including the timing and size of scheduledpayments. Comment 1041.3(b)(1)-3. For example, a loan is substantially repayablewithin 45 days if the lender has the right to be repaid through a sweep or withdrawalof any qualifying electronic deposit made into a consumer’s account within 45 days ofconsummation or an advance (as applicable), even if no qualifying electronic depositis actually made. Comment1041.3(b)(1)-4.“Consummation” is the time that theconsumer becomes contractually obligated onA loan is not substantiallya new loan or on a modification that increasesrepayable within 45 days merelythe amount of an existing loan. 12 CFRbecause a consumer chooses to1 041.2(a)(5). When a consumer becomesrepay within 45 days if the loancontractually obligated is a matter to beterms do not require the consumerdetermined by applicable law, such as state orto do so. Comment 1041.3(b)(1)-3.local law. Consummation does not occurHowever, if under any applicablemerely because the consumer has made somelaw, a consumer would breach thefinancial investment in the transaction (e.g.,loan agreement by notpaid a non-refundable fee), unless applicablesubstantially repaying the entirelaw holds otherwise. Comment 1041.2(a)(5)-1.amount of the loan within 45 daysof consummation or to repay asubstantial majority of anyadvance within 45 of the advance (as applicable), the loan is substantially repayablewithin 45 days. Comment 1041.3(b)(1)-5.4. Does not satisfy an exclusion set forth in the Payday Lending Rule. Section 2.4discusses exclusions under the Payday Lending Rule.5. Does not satisfy a conditional exemption set forth in the Payday Lending Rule.Section 2.5 discusses conditional exemptions under the Payday Lending Rule.12 CFR 1041.3(b)(1).12SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

2.2Covered longer-term balloonpayment loansA loan is a covered longer-term balloon-payment loan if it meets all of the following, asapplicable:1. Is not a covered short-term loan. Section 2.1 discusses the criteria for covered shortterm loans.2. Is an extension of credit to a consumer (i.e., an individual or an individual’s agent ortrustee).3. Is extended primarily for personal, family, or household purposes. Lenders may relyon Regulation Z, 12 CFR 1026.3(a) and its related commentary, when determining theprimary purpose of a loan. Comment 1041.3(b)-2.4. For closed-end credit that provides for a single advance, satisfies either of thefollowing conditions:a. The consumer is required to repay the entire balance of the loan in a singlepayment more than 45 days after consummation; orb. The consumer is required to repay the loan through at least one payment that ismore than twice as large as any other payment(s). All required payments dueunder the loan are used to determine whether a particular payment is more thantwice as large as another payment, regardless of whether payments have changedduring the loan term due to rate adjustments or other payment changes permittedor required under the loan. This includes required payments of principal (if any)and charges, except charges for actual unanticipated late payments, charges forexceeding the credit limit, and charges for delinquency, default, or a similaroccurrence. Comments 1041.3(b)(2)-2 and -3. Sums that are accelerated and dueupon default are excluded from the determination. Comment 1041.3(b)(2)-3.5. For open-end credit and closed-end credit that provides for multiple advances,satisfies any of the following conditions:a. The consumer is required to repay substantially the entire amount of anadvance in a single payment more than 45 days after the advance is made.13SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

b. The consumer is required to make at least one payment on an advance that ismore than twice as large as any other payment(s). All required payments dueunder the loan are used to determine whether a particular payment is morethan twice as large as another payment, regardless of whether payments havechanged during the loan term due to rate adjustments or other paymentchanges permitted or required under the loan. This includes requiredpayments of principal (if any) and charges, except charges for actualunanticipated late payments, charges for exceeding the credit limit, andcharges for delinquency, default, or a similar occurrence. Comments1041.3(b)(2)-2 and -3. Sums that are accelerated and due upon default areexcluded from the determination. Comment 1041.3(b)(2)-3.c. The loan is structured such that paying the required payments may not fullyamortize the outstanding balance by a specified date or time; AND theamount of the final payment to repay the outstanding balance at such timecould be more than twice the amount of other minimum payments.Example: Willow Lender extends an open-end credit plan to aconsumer primarily for personal, family, or household purposes.The plan has a 500 credit limit, monthly billing cycles, and amonthly minimum payment that is equal to 10% of the outstandingprincipal. All outstanding amounts must be repaid within sixmonths of the advance. Assume the fees and interest equal 10% ofthe outstanding principal, and that the outstanding principalremains the same if the consumer pays nothing other than theminimum payment amount. Unless an exclusion or conditionalexemption applies, the loan is a covered longer-term balloonpayment loan because the sixth payment would be more than twicethe amount of the minimum required payment if the consumerdrew the entire amount at one time and made only minimummonthly payments.14SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

6. Does not satisfy an exclusion set forth in the Payday Lending Rule. Section 2.4discusses exclusions under the Payday Lending Rule.7. Does not satisfy a conditional exemption set forth in the Payday Lending Rule.Section 2.5 discusses conditional exemptions under the Payday Lending Rule.12 CFR 1041.3(b)(2)(i).2.3Covered longer-term loansA loan is a covered longer-term loan if it meets all of the following, as applicable:1. Is not a covered short-term loan or a covered longer-term balloon loan. Section 2.1discusses the criteria for covered short-term loans, and Section 2.2 discusses thecriteria for covered longer-term balloon-payment loans.2. Is an extension of credit to a consumer (i.e., individual or an individual’s agent ortrustee).3. Is extended primarily for personal, family, or household purposes. Lenders may relyon Regulation Z, 12 CFR 1026.3(a) and its related commentary, when determining theprimary purpose of a loan. Comment 1041.3(b)-2.4. For closed-end credit, satisfies both of the following conditions:a. The cost of credit for the loan exceeds 36 percent per annum at the time ofconsummation. “Cost ofcredit” means the cost ofA loan is a covered longer-term loan only if itconsumer credit expressed as asatisfies both the 36% cost of credit (i.e.,per annum rate. The cost ofcredit includes all financecharges as set forth inRegulation Z, 12 CFR 1026.4,but without regard to whetherthe credit is consumer creditAPR) requirement and the leveragedpay ment mechanism requirement. Forex ample, a 60-day loan is not a coveredlonger-term loan if the cost of credit asmeasured pursuant the Payday Lending Ruleis less than or equal to a rate of 36%, even ifthe lender or service provider obtains aor is extended to a consumerlev eraged payment mechanism. Commentas those terms are defined in1 041.3(b)(3)-1.Regulation Z, 12 CFR1026.2(a)(11) and (12). 12 CFR 1041.2(a)(6)(i).15SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

For closed-end credit, the cost of credit must be calculated according to therequirements of Regulation Z, 12 CFR 1026.22. 12 CFR 1041.2(a)(6)(ii)(A).Under Regulation Z, the cost of credit is expressed as the Annual PercentageRate or APR. Thus, closed-end credit satisfies this condition if the APRproperly disclosed on the Truth-in Lending disclosure at consummationexceeds 36 percent.b. At any time during the loan term, the lender or a service provider obtains aleveraged payment mechanism. A lender or service provider7 obtains aleveraged payment mechanism if it has the right to initiate a transfer of money,through any means, from a consumer’s account 8 to satisfy an obligation on aloan. Comment 1041.3(c)-1. This includes, for example, the right to initiate atransfer from a consumer’s account by means of a check, an electronic fundtransfer, a remotely created check or payment order, or a transfer by anaccount-holding institution. Comment 1041.3(c)-2.A lender or service provider obtains the ability to initiate a transfer from aconsumer’s account when it can collect payment or otherwise draw funds froma consumer’s account (either on a single occasion or on a recurring basis)without the consumer taking further action. Generally, when a lender orservice provider has the ability to “pull” funds or initiate a transfer from aconsumer’s account, that person has a leveraged payment mechanism.However, a “push” transaction from the consumer’s account to the lender orservice provider does not in itself give the lender or service provider aleveraged payment mechanism. Comment 1041.3(c)-1.A lender or service provider does not obtain a leveraged payment mechanismby initiating a single immediate payment transfer at a consumer’s request. 127“ Service prov ider” has the same m eaning as in the Dodd-Frank W all Street Reform and Consumer Protection Act(Dodd-Fr ank Act), 1 2 U.S.C. 5481(26). See Section 3 for m ore information on service prov iders.8 “ A ccount” has the same meaning as in Regulation E,12 CFR 1 005.2(b). Generally, the term includes a demanddeposit (checking), savings, or ot her consumer a sset account established for personal, family, or h ouseholdpu r poses and held by a financial institution. It includes prepaid accounts a s defined in Regulation E.16SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE 3.0

CFR 1041.3(c). Section 4.5 provides additional information on singleimmediate payment transfers at a consumer’s request, but a single immediatepayment transfer at a consumer’s request is generally a one-time transferinitiated within one business day after the consumer proffers a check orauthorizes an electronic transfer. 12 CFR 1041.8(a)(2).This condition is satisfied if a lender or service provider obtains a leveragedpayment mechanism before, at the same time as, or after the consumerreceives the entire amount of the loan proceeds and regardless of the means bywhich the lender or service provider obtains the leveraged paymentmechanism. Comment 1041.3(b)(3)(ii)-1. This condition is satisfied if a loanagreement authorizes the lender

Payday L ending Rule's mandatory underwriting provisions to November 19, 2020 and made technical corrections to the 2017 Payday Lending Rule. On July 7, 2020, the Bureau issued a . (NCUA 's) requirements for the Payday Alternative Loan (PAL) program set forth in 12 CFR 701.21(c)(7)(iii)are exempted from being covered loans . E ight

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