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

Published: Oct. 1, 2020, 11:42 a.m.

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.