2020Directory_FNL_FlippingBook
Compliance Obligation
Federal Laws that Apply
Violations / Penalties
Short-term loans payable within 45 days; Longer-term single-payment or installment loans with balloon payments; and Installment
CFPB Small Dollar Rule
Relief may include: • rescission or reformation of contracts; • refund of moneys or return of real property; • restitution; • disgorgement or compensation for unjust enrichment; • payment of damages or other monetary relief; • public notification regarding the violation, including the costs of notification; • limits on the activities or functions of the person; and • civil money penalties • $5,000 per day that the violation continues. • If reckless violation, $25,000 per day that the violation continues. • If knowing violation, $1,156,242 per day that the violation continues. 12 U.S.C. § 5565(a), (c).
HOT TOPICS
loans with an annual percentage
rate over 36% repayable with a leveraged payment mechanism
227 2020 MEMBERSHIP DIRECTORY & SERVICES GUIDE
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