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ARTICLE · 17 JUNE 2016

Cadwalader Attorneys Review CFPB's Payday Loans Proposal

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Hogan Lovells Cadwalader

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Cadwalader attorneys examined the "long-awaited" proposal by the Consumer Financial Protection Bureau ("CFPB") of rules governing payday loans and other "high-cost" credit products.

United StatesConsumer Protection
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Cadwalader attorneys examined the "long-awaited" proposal by the Consumer Financial Protection Bureau ("CFPB") of rules governing payday loans and other "high-cost" credit products. The proposal includes a requirement that lenders take steps to ensure prospective borrowers have the ability to repay loans. The proposed rules would apply to physical and online banks, credit unions, and other lenders regardless of how they are licensed under state law. If approved, the attorneys noted, the rules would impose substantial new compliance and recordkeeping obligations on lenders who provide certain kinds of short- and long-term loans to consumers. Given the imminence of that possibility, the attorneys struck a note of caution:

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