With the Rule’s August 19, 2019 compliance date drawing nearer, industry anxiety is growing as to the CFPB’s plans for delaying the Rule's compliance date and what changes will be proposed. In this episode, we review what the Rule's ability to pay and repayment provisions would require and why those provisions are problematic. We also discuss changes we expect the CFPB to propose, developments in the lawsuit challenging the Rule, and steps companies can take in advance of the compliance date.