2023 Compliance Trends: Staying Ahead in an Evolving Regulatory E...
Credit unions will face a complex and busy regulatory compliance environment in 2023. With a major r ...
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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.
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