CUNA’s Compliance team has received a number of questions regarding which provisions of the Consumer Financial Protection Bureau’s short-term, small-dollar (payday) loan rule are delayed and which will become effective in August.
In response, staff has created a CompBlog entry detailing the effective dates.
The CFPB finalized the payday rule in November 2017, and it addresses two separate topics:
A June 6 final rule from the CFPB delays the compliance date for most of the Mandatory Underwriting Provisions to Nov. 19, 2020 (they were originally set to go into effect Aug. 19 of this year).
See the CompBlog entry for a specific list of provisions extended to Nov. 19, 2020, provisions not extended will become effective Aug. 19.
The CFPB has not proposed to rescind the Payment Provisions as finalized in 2017.