Abstract

http://ssrn.com/abstract=2160542
 


 



America's First Consumer Financial Watchdog Is on a Leash: Can the CFPB Use Its Authority to Declare Payday-Loan Practices Unfair, Abusive, and Deceptive?


Creola Johnson


Ohio State University - Michael E. Moritz College of Law

January 1, 2012

Catholic University Law Review, Vol. 61, 2012

Abstract:     
To stop payday lenders from skirting state laws, this Article asserts that the CFPB should exercise its rulemaking authority to declare many payday loan practices as unfair, deceptive, abusive, and, consequently, unlawful.

The CFPB's imposition of restrictions on payday loans will not end short-term, small-dollar loans in America, but will cause an increased prevalence of responsible lending practices. The results of a recent pilot program implemented by the Federal Deposit Insurance Corporation (FDIC) demonstrate that lenders can issue small-dollar loans subject to the types of restrictions proposed above and still achieve long-term profitability. Therefore, the CFPB's regulatory intervention will correct the continuing market failure by promoting profitable, yet fair loans by responsible lenders.

Accepted Paper Series





Not Available For Download

Date posted: October 12, 2012  

Suggested Citation

Johnson, Creola, America's First Consumer Financial Watchdog Is on a Leash: Can the CFPB Use Its Authority to Declare Payday-Loan Practices Unfair, Abusive, and Deceptive? (January 1, 2012). Catholic University Law Review, Vol. 61, 2012. Available at SSRN: http://ssrn.com/abstract=2160542

Contact Information

Creola Johnson (Contact Author)
Ohio State University - Michael E. Moritz College of Law ( email )
55 West 12th Avenue
Columbus, OH 43210
United States
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