Archive: 16 January 2018

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Payday Loan Rule Is Officially A Go—Or Is It?

Payday Loan Rule Is Officially A Go—Or Is It?

By Jennifer Janeira Nagle and  Robert W. Sparkes III

Today, January 16, 2018, officially marks the effective date of the Consumer Financial Protection Bureau’s final rule targeting what it refers to as “payday debt traps” (the “Rule”).  As outlined in our previous publications (found here and here), the Rule marks a significant change in the landscape for lenders offering short-term loans or longer-term loans with balloon payments, including payday and vehicle title loans.  Looming large is the new requirement that lenders determine a borrower’s ability to repay prior to originating covered loans.

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