Credit Union National Association
CFPBRulemakingCFPB-2019-0006

Payday, Vehicle Title, and Certain High-Cost Installment Loans

RIN
Last modified
Oct 25, 2022
Comment window
closed 2631d ago
Credit Union National Association filings
2

Activity

Credit Union National Association filed 2 comments on this docket between Mar 21, 2019 and Apr 22, 2020. 78 other organizations filed here. The comment window closed 2631d ago.

What Credit Union National Association filed (2)

Apr 22, 2020· Ex parte submission by Jim Nussie, Credit Union National Association (CUNA)· CFPB-2019-0006-188547

Filed on regulations.gov — full text not in the inline record.

Mar 21, 2019· Comment submitted by Elizabeth Eurgubian, Credit Union National Association· CFPB-2019-0006-0319

Filed on regulations.gov — full text not in the inline record.

Abstract

The Bureau of Consumer Financial Protection (Bureau) is proposing to rescind certain provisions of the regulation promulgated by the Bureau in November 2017 governing Payday, Vehicle Title, and Certain High-Cost Installment Loans (2017 Final Rule or Rule). The provisions of the Rule which the Bureau proposes to rescind provide that it is an unfair and abusive practice for a lender to make a covered short term or longer term balloon payment loan, including payday and vehicle title loans, without reasonably determining that consumers have the ability to repay those loans according to their terms; prescribe mandatory underwriting requirements for making the ability to repay determination; exempt certain loans from the mandatory underwriting requirements; and establish related definitions, reporting, and record keeping requirements. This proposal is related to another proposal, published separately in this issue of the Federal Register, seeking comment on whether the Bureau should delay the August 19, 2019 compliance date for these portions of the 2017 Final Rule.

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