Payday Loans, Small Dollar Lending, and Litigation and Enforcement Trends Related toCompanies Offering Advancements on Settlement Payouts to Consumers
- CFPB’s payday loan rule
- determining extent of ability of creditors to provide credit
- focus on APR but realizing overhead costs for lenders
- Companies offering payment in exchange for purchasing piece of settlement when and if the case settles
- Is this product considered a loan extension of credit or a purchase of an asset
- Does the CFPB have authority to regulate and enforce in this area?
- CFPB v. RD LEGAL