The CFPB recently announced the details of the payday loan rule that it is considering proposing. While it nominally targets traditional short-term, small-dollar lending that is commonly referred to as “payday lending,” the scope of the rule under consideration would more broadly cover vehicle title loans, deposit advance products, and certain high-cost installment and open-end loans. The authors of this article discuss the complexities of the proposed rule including the rulemaking process, potential timing, scope, and requirements.
