Do you do balloon loans or any short-term loans not secured by real property?
If so, you could find yourself subject to the Payday Loan Rule.
Now, there are several types of loans that are not subject to the Rule, including purchase-money loans and loans secured by real property. In addition, there are exemptions for loans and/or lenders meeting certain conditions.
However, one of these exemptions will require periodic “look-backs” to make sure you continue to fall within certain thresholds. The loans that could fall subject to the Rule really go beyond what you may think of for a “Payday Loan”. Even if your plan is to avoid making loans subject to this Payday Rule, you will need to understand what’s covered and what’s not.
Listen to the video as Kevin explains some solutions we have coming up.
Published
2019/04/16
Kevin Edwards
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Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).