The Payday, Vehicle Title, and Certain High-Cost Installment Loans (Payday) Rule has been unfolding for years. With most new rules the options are comply or die – either fully implement the rule or risk violations. With the Payday Rule we have advocated for several years that the option is compliance or avoidance. Either build a comprehensive compliance management system to cope with the 1,700 page rule, take advantage of allowed exceptions, or make a few changes to your product line-up to eliminate a few low-volume products that are covered by the rule.
Most depository institutions do not make a large volume of “covered loans”.
For additional resources on the topic of Payday Lending Rules visit the following pages: