On February 20, the Consumer Financial Protection Bureau released a compliance guide for small entities that summarizes payment-related provisions of the Payday Lending Rule.

The Payday Lending Rule governs payday loans, vehicle tile loans, and certain high-cost installment loans.  The Guide focuses on the payment provisions of the Payday Lending rule, found in Subpart C of the Rule.  It also discusses general coverage provisions, including lenders and servicers subject to its mandates, prohibited payment transfer attempts, and disclosure of payment transfer attempts, which are found in Subpart A of the Rule.  Lastly, the Guide focuses on the record retention and compliance program requirements, found in Subpart D of the Rule.

The Guide should be reviewed in conjunction with the Rule as the Guide does not include interpretations issued or released after February 2019.

A copy of the Guide can be found here.

Troutman Sanders will continue to monitor and report on developments regarding the CFPB.