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Reminder: CFPB's Small Dollar, Vehicle Title, Payday Loan Proposal Comments Due Oct. 7
Friday, September 30, 2016 6:00 AM

Cornerstone is still actively soliciting our credit unions to comment on the Consumer Financial Protection Bureau's most recent proposal on small-dollar, vehicle title, and payday loans.

This proposed rule would heavily regulate most loans under 45 days and certain loans with a term of more than 45 days (that exceed a rule-determined “all-in APR” or 36 percent). Loans covered by this rule would be subject to an ability-to-repay analysis during the underwriting process, along with certain collections, tracking, and reporting requirements.

The rule provides several limited exceptions for loans over 45 days, including a partial but not complete exemption for National Credit Union Administration’s payday alternative lending (PAL) program. 

CUNA anticipates that if the rule were to pass as written, it would greatly impact many loan products, especially short-term, small loans, and those that refinance existing vehicle loans. All credit unions are requested to send in their comments as soon as possible.

More information on the proposal can be found in CUNA’s detailed analysis of the proposal and through a recording of CUNA’s webinar on the rule, free for members. 

If you need help in crafting comment letters, or if you have questions about this proposal, please contact Cornerstone Credit Union League SVP Regulatory Compliance Suzanne Yashewski at or 512-853-8516.