Summary: Final Rule on Payday, Vehicle Title and Certain High-Cost Installment Loans; Delay of Compliance Date; Correcting Amendments

Bureau of Consumer Financial Protection
Prepared by the NASCUS Legislative & Regulatory Affairs Division
June 2019

The Bureau of Consumer Financial Protection (Bureau) is issuing this final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the regulations promulgated by the Bureau in November 2017 governing Payday, Vehicle Title and Certain High-Cost Installment Loans.  The compliance date for the mandatory underwriting provisions of the 2017 final rule have been delayed until November 19, 2020.

The amendments to the 2017 final rule become effective on August 16, 2019.  You can access the final rule here.

Summary

The Bureau issued this final rule to delay the compliance date for the mandatory underwriting provisions of the 2017 final rule because:

  • It believes it has strong reasons to revisit the mandatory underwriting provisions on the grounds provided in the NPRM that reconsiders the 2017 final rule and
  • It concludes that if the mandatory underwriting provisions went into effect in August 2019 while the Bureau was still considering the appropriateness of the 2017 FR there would be detrimental consequences for businesses that are impacted.

The delayed compliance date applies specifically to Sections 1041.4 through 1041.6, 1041.10 and 1041.12(b)(1) through (3). The final rule also makes conforming amendments to certain regulatory text and commentary adopted in the 2017 final rule to reflect the compliance date delay as well as supplementing the Rule with an additional Section (1041.15) that provides details regarding its effective and compliance dates.

06/20/19