September 22, 2019

September 20, 2019

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Payday Lending Rule, New Fed Governor, and Other Developments Make for a Busy Week in Washington

October in Washington, DC is typically busy, marking the start of a new fiscal year for the federal government, a new term of the Supreme Court, and, this year, a lot of activity by financial regulators and Congress.

Just this week:

  • There were two hearings in the Senate Banking Committee on consumer protection.

  • The Senate confirmed Randal Quarles as the newest member of the Board of Governors of the Federal Reserve System (the Federal Reserve Board) by a 65–32 vote.

  • The CFPB released its long-awaited and much discussed,  final rules regulating payday loans, vehicle title loans, and certain other high-cost loans (the Payday Lending Final Rule).

  • The OCC rescinded its 2013 Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products in response to the Payday Lending Final Rule.

The Payday Lending Final Rule has received the most notice, and at almost 1,700 pages it is difficult not to notice it. Although it doesn’t go into effect for another 21 months or so, the Payday Lending Final Rule is certain to have a significant impact on the payday lending and vehicle title loan industry, and it may well have ancillary effects on other consumer financial services products. We will share more thoughts on the potential impacts of the Payday Lending Final Rule in the coming weeks.

Once Randal Quarles begins his term, the Federal Reserve Board will have only five members, with two remaining vacancies. He is filling a vacancy left by the resignation of former Federal Reserve Board member Jeremy Stein, and will serve the rest of that unexpired 14-year term, meaning that Quarles’s term will be up for renewal in early 2018, around the same time that Federal Reserve Board Chair Janet Yellen’s term expires. Another vacancy is expected in the next few weeks, as Vice Chair Stanley Fischer has announced he will step down sometime in October. If the Trump administration can nominate and get Senate confirmations for individuals to fill all of the Federal Reserve Board’s current and upcoming vacancies, the Federal Reserve Board will look quite different a year from now.

Copyright © 2019 by Morgan, Lewis & Bockius LLP. All Rights Reserved.

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About this Author

Melissa R.H Hall, Financial services attorney, Morgan Lewis
Of counsel

Melissa R. H. Hall represents US and overseas banks, nonbank financial services companies, investors in financial services, and technology companies in regulatory and corporate matters. She advises them on a wide range of state and federal financial regulatory laws and regulations. She provides counsel on financial regulatory compliance and enforcement, including state and federal licensing requirements, consumer financial products and compliance, payment systems, corporate and transactional matters, financial institution investment and acquisition, and the development...

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