On October 5, 2017, the Consumer Financial Protection Bureau (CFPB) released the “Payday Lending Rule,” the much-anticipated rule regulating payday and other small consumer loans. The core of the rule is a new ability-to-repay underwriting requirement for short-term loans and certain longer-term balloon loans. In this Legal Update, we describe the Payday Lending Rule’s requirements and potential effects on creditors offering payday loans and/or payday alternative credit products, as well as the broader consumer financial industry.
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