Credit unions making small dollar, shorter term ‘payday’-type loans will want to take a look at the Consumer Financial Protection Bureau’s proposal issued today. Comments are due to the CFPB 9/14/2016.
Links to a copy of the proposal, the CFPB’s summary, and a CFPB release on the proposal are at the bottom of this post. The agency’s summary is on on pages 3-11 of the CFPB proposal. Short term loans that meet the limits of NCUA’s PALs program would be exempt from the ability to repay requirements under the proposal but would be subject to other provisions.
The agency is also seeking comments through 10/14/2016 on other products that may be similar or unrelated but do not fit neatly under the payday loan proposal. A link to the release and request for information on that CFPB initiative is also below. We will be blogging more about the proposal and key points to address issues of interest and concern to credit unions.