There are many firsts in life worth celebrating. For many lenders who issue short-term/payday loans, the Consumer Financial Protection Bureau’s (CFPB) first rule based on its authority to issue enforcement actions for what it deems to be unfair, deceptive or abusive acts or practices (UDAAP) is not one of those.
Venable Partner and former CFPB Senior Counsel Andrew Arculin spoke with Dodd Frank Update about how great a threat the new rule poses to lenders specializing in short-term, small-dollar loan products, considering the potential UDAAP implications of failing to comply with its terms.
Read on to find out more about what they had to say on the matter.