All of us at EPIC Loans hope this note finds you safe and successful during these unprecedented times. As summer of 2020 is in full swing, we wanted to keep in touch and continue to share news about our activities that will interest you. EPIC is committed to staying abreast of industry trends and activities to ensure that our LMS is up to date and meeting your needs.
CFPB Issues Final Payday Loan Rule
EPIC Is Ready!
As everyone likely knows by now, the Consumer Financial Protection Bureau (CFPB) issued its final rule on July 7, 2020 and it goes into effect on November 19, 2020.
As background, in October 2017, during the leadership of Obama-appointed Director Richard Cordray, the CFPB finalized a rule covering Payday, Vehicle Title, and Certain High-Cost Installment Loans. That rule asserted that it is “an unfair and abusive practice” for a lender to make certain types of short-term, small-dollar loans “without reasonably determining that consumers have the ability to repay the loans,” also called loan underwriting. The 2017 rule, which mandated underwriting provisions, exempted some short-term, small-dollar loans if made with certain loan features. The rule as issued last month, rescinds these mandatory underwriting provisions.
The updated Rule in its current form will still require the payment provisions that were part of the 2017 version and will be taking effect in November. These provisions prohibit lenders from making a new attempt to withdraw funds from an account where two consecutive attempts have failed unless consumers consent to further withdrawals. The payment provisions also require such lenders to provide consumers with written notice before making their first attempt to withdraw payment from their accounts and before subsequent attempts that involve different dates, amounts, or payment channels. Fortunately, a petition to commence a rulemaking to exclude debit and prepaid cards for the payments provisions of the rule were denied by the agency.
Anticipating these provisions of the Rule, EPIC is ready with updates to our LMS to be fully compliant for the November implementation.
The final rule can be viewed here.
Don’t Forget! LendConnect Webinar
EPIC Loan Systems continues to expand its reach beyond its annual LendConnect conference with periodic webinars to stay connected and share timely industry information
This session will be hosting an informative panel will discuss:
- How data providers and lead generators continue to help lenders identify the ever changing challenges in our marketplace
- Adjusting underwriting strategies to help lenders adapt and manage through the current economic climate
- Planning for a successful 4th Quarter
Director of Sales
EPIC Loan Systems
Senior Vice President
An Equifax Company
Senior Vice President,
Zero Parallel, LLC