Just two days before its Payday, Vehicle Title, and Certain High-Cost Installment Loans final rule was slated to go into effect (and eight years after it was finalized), the Consumer Financial Protection Bureau (CFPB) announced on March 28 that it "will not prioritize enforcement or supervision actions with regard to any penalties or fines associated with the Payment Withdrawal provisions and the Payment Disclosure provisions [of the rule] once they become operative on March 30, 2025."
Rather, the CFPB stated that it will "keep its enforcement and supervision resources focused on pressing threats to consumers, particularly servicemen and veterans," and that the CFPB "takes this step in the interest of focusing resources on supporting hard-working American taxpayers, servicemen, veterans, and small businesses."
The press release does not impact the ability of state regulators to bring enforcement actions related to violations of the rule, as state regulators may bring federal consumer financial protection claims under Title X of the Dodd-Frank Act, and the rule was promulgated pursuant to such.
The CFPB also announced that it is also considering a reevaluation of the rule, and as a result, may issue a proposed rule to narrow the scope of the rule.
Visit Holland & Knight's resource center, CFPB Dispatch: Legal Updates and Insights, to stay on top of the latest CFPB developments.
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