On June 6, 2019, the Consumer Financial Protection Bureau (CFPB) issued an 87-page final rule to delay by 15 months the underwriting provisions of the payday lending regulation. The CFPB is delaying the August 19, 2019 compliance date for the mandatory underwriting provisions of the payday, vehicle title and certain high-cost installment loans (2017 final rule). Financial institutions now have until November 19, 2020 to comply with the underwriting requirements. The CFPB also made corrections to the 2017 final rule related to several clerical and non-substantive errors it identified.



John Zasada, JD, CAMS – Regulatory Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.