b'Payday + Small Dollar LendingNumber of Actions Amount of Recovery2631 $96.2M 13$1.5M $84.2M17$50.7M13$17.8M2016 2017 2018 2019 2020directly from a consumers bank account. In July, theallegedly failed to maintain adequate policies and CFPB rescinded several of the rules key underwritingprocedures for furnishing accurate information to credit provisions in their entirety, on the ground that thereporting agencies, potentially affecting the accuracy Bureau had re-evaluat[ed] the legal and evidentiaryof information furnished concerning some 20,000 bases for these provisions and [found] them to beconsumers. Under the terms of the consent order, insufficient. The July revisions scrapped a requirementCottonwood Financial agreed to pay $286,675 in that lenders determine a borrowers ability to repayconsumer redress and $1.1 million in civil penalties. before making a covered loan, as well as a requirement that lenders verify a consumers income. The revisionsCFPB Settles Claims Against Main Street Personal also eliminated certain definitions related to theFinance and Its Subsidiaries over Finance Chargesunderwriting provisions, such as identifying as an unfairIn June, the CFPB reached a settlement with and abusive practice making covered loans without firstTennessee-based payday and title loan lender Main determining a borrowers ability to repay. The BureauStreet Personal Finance, Inc. and its subsidiaries. The contends that consumers will continue to have robustCFPB alleged that the companies provided deceptive consumer protections pursuant to the CFPAs UDAAPdisclosures, failed to refund overpayments on loans, provisions, the payments provisions of the 2017 rule,and engaged in unfair debt collection practices. The and other provisions of federal and state law. CFPB alleged, for example, the companies concealed or understated finance charges on auto-title loans CFPB Enters Consent Order with Cottonwoodfor over 4,000 customers, and that customers paid Financial, Ltd. Over Unfair and Deceptive Practices $3.5million more in finance charges than were actually In April, the CFPB entered into a consent order withdisclosed. The companies also allegedly made illegal Cottonwood Financial, Ltd., which operates undercalls to consumers places of work and disclosed the name Cash Store, resolving allegations that thecustomers debts to third parties. The consent order payday lender violated the CFPA, FCRA, and TILAprohibits the companies from misrepresenting its by making deceptive representations to consumersfinance charges on auto-title loans, requires timely in television ads and through direct telemarketing,refunds of non-disclosed finance charges, prohibits phoning consumers places of work even afterunlawful debt collection practices, requires that the being asked to stop, and disclosing the existence ofcompanies pay $2 million in consumer redress, and consumers debts to third parties. The lender alsoimposes a $1 civil money penalty.37'