Consumer Finance Monitor

A Close Look at the CFPB’s Exam Findings Related to Short-Term Small-Dollar Lending in Summer 2020 Supervisory Highlights


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We review the CFPB’s findings that lenders engaged in deceptive practices and violated Reg. Z advertising rules based on the following conduct and discuss compliance implications: false representations about consumers’ ability to apply for loans online and the absence of credit checks; false threats of liens, asset seizures and late fees in collection letters; and advertising “free loans” without including additional information required when using a “triggering term” or where loan was free only if prepaid.

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Consumer Finance MonitorBy Ballard Spahr LLP

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