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John Zasada, Compliance Consulting Director, Financial Institutions Group
On Dec. 4, 2020, the Consumer Financial Protection Bureau (CFPB) filed a complaint against LendUp Loans, LLC (LendUp), an online lender offering single-payment and installment loans to consumers, for violating the Military Lending Act (MLA).
The complaint alleges since 2016, LendUp made 4,100 loans to MLA-covered borrowers with Military Annual Percentage Rates (MAPRs) greater than 36%. In addition, in violation of the MLA, LendUp required borrowers to sign loan agreements containing arbitration clauses in the case of a dispute. Finally, LendUp failed to provide MLA loan disclosures to borrowers before or at the time the borrower became obligated on the loan. The complaint itself is not a ruling that LendUp violated the MLA.
For more information on the MLA compliance requirements, please contact one of Doeren Mayhew’s regulatory compliance specialists.
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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