CFPB Updates Payday Section of the Supervision and Examination Manual
The CFPB recently updated the Short-Term, Small-Dollar Lending (i.e., Payday Lending) examination procedures, dated March 2019, in their Supervision and Examination Manual.
The examination procedures include five modules that cover a payday loan’s lifecycle. Each module includes relevant matters to be examined, and the modules are titled:
- Marketing
- Application and Origination
- Payment Processing and Sustained Use
- Collections, Accounts in Default, and Consumer Reporting
- Service Provider Relationships
Please also see WBK’s federal industry news article dated March 7, 2019, regarding the CFPB’s Small Entity Compliance Guide for the Payday Lending Rule.