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Course description

The Payday Lending Rule's general compliance date was supposed to be August 19, 2019. That date, however, is currently stayed (delayed) under an order in a federal court case challenging the CFPB's legitimacy and the validity of the Rule. As a result, lenders have no obligation to comply with the Rule until the court-ordered stay is lifted.

Earlier this year, the Supreme Court cleared up  the legal status of the CFPB when it ruled that the Bureau’s management structure was unconstitutional because the director could only be dismissed by the president for cause, but ordered that the language of the law be changed to provide for dismissal at the will of the president. That hasn’t satisfied the plaintiff in the lawsuit filed in the federal court in Texas. We’ll discuss the plaintiff’s stance and any developments that may change the status of the Rule.

Is your bank ready? Have you figured out whether you make loans that will be subject to the rule? Will your bank qualify for an important exemption from the Rule's requirements?

In this one-hour presentation, you will --

  • get a quick and easy way to determine whether loans your bank makes will be subject to the rule
  • learn how to determine whether your bank qualifies for an exemption
  • get the latest news on the rule's compliance date


In addition to those important topics discussed in our presentation, you'll also get written materials with information on what your institution needs to do if the stay is lifted and the rule becomes effective. It covers

  • The scope of loans covered by the rule
  • Exemptions from coverage
  • The role of "leveraged payment mechanisms"
  • Alternative loans
  • Credit union small loans
  • Accommodation loans
  • Permitted and prohibited methods for obtaining payments
  • Borrower authorizations for payments
  • Required disclosures related to payment authorizations
  • Required notices of payment attempts
  • Recordkeeping requirements
  • Severability of requirements
  • … and more

 

WHO SHOULD ATTEND:

Compliance officers, audit personnel, consumer lenders, lending management

 

Instructor(s)

John Burnett

John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the BankersOnline.com team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.

Course curriculum

  • 1

    Webinar

    • Access Webinar

  • 2

    Materials

    • Materials

    • Slides

    • Questions and Answers

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