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CFPB Payday Lending Rules 2.0 — What’s Next

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While there were many provisions to the payday lending rules as originally passed, the one that caused the greatest controversy was the “ability to repay” provision that would have required short-term lenders to establish a borrower’s ability to repay before offering them a small-dollar, short-term lending product. The Path To Revision.

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Morgan Lewis Principal Weighs In On Payday Loan Debate

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That would entail verification of a borrower’s income, debt and spending habits. Alternatively, the lender could choose to sidestep that verification process and change the loan to an installment offering, with a set time frame and payment schedule agreed to at the time of issuing the loan.