So, what does this mean for you? Below are five key issues that you should consider when creating a Small Dollar Rule compliance plan.

While compliance with the Small Dollar Rule is currently stayed pending the outcome of litigation between a trade association and the Bureau, finance companies may need to comply with the Small Dollar Rule soon. The Rule also requires finance companies making covered loans to send three different types of payment notices to borrowers. The payment provisions impose requirements regarding payment attempts - specifically, prohibiting subsequent payment attempts following a second consecutive failed payment transfer without a new authorization. As a result, all that remains are the 'payment provisions.' The Rule, originally proposed in 2016, has undergone a wild ride - from being 'finalized' in 2017 to having substantial sections rescinded in 2020, including the mandatory underwriting provisions. In July 2020, the Consumer Financial Protection Bureau ('Bureau') at long last finalized the Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans ('Small Dollar Rule' or 'Rule'). SeptemIt's the Final Countdown: The Small Dollar Rule's Looming Compliance Date

Small countdowns