How Do the New CFPB Regulations Impact the QCash Financial Platform and Credit Unions?

What are the new CFPB regulations for small dollar loans and payday lending for credit unions?

In late 2017, the Consumer Financial Protection Bureau (CFPB) finalized new regulations for small-dollar loans and payday lending.

QCash, a subsidiary of Washington State Employees Credit Union (WSECU), has engaged in conversations throughout the process, including WSECU President & CEO, Kevin Foster-Keddie who participated in the CFPB credit union roundtable. Foster-Keddie provided feedback to CFPB and shared the QCash experiences about short-term, small-dollar lending concepts as it applies to credit union members.

For QCash, the involvement in the new rule formation has been essential to understanding the impact on the platform and credit unions…

New CFPB Small-Dollar Loan Rule for Non-Covered Loans

The new small-dollar loan rule provides more regulatory guidance around non-covered and covered loans to borrowers who may be unable to pay the high fees typically attached with payday loans. CFPB cites that payday loans often force borrowers into another, short-term loan with an inability to pay, calling this process a “debt trap” for consumers.

Credit unions, however, have long provided members with Payday Alternative Loan (PAL) programs. These short-term, small-dollar loans are less costly for members than traditional payday lending.

The new CFPB rule provides a safe harbor for programs like the QCash financial platform and its non-covered loans, making it exempt from added regulatory burdens.

What is a Non-Covered Loan?

The CFPB defines a non-covered loan with an annual percentage rate (APR) of less than 36% and repayment terms that are greater than 45 days. These non-covered loans are exempt from additional regulations.

Covered loans (parameters greater than non-covered loans) will require supporting documentation from the institution, mostly focused on the borrower’s ability to repay.

QCash Automation Provides Compliance Assurance

QCash, developed before new CFPB regulations, is based on the premise that automation is necessary to deliver short-term, small-dollar loans. QCash’s automated workflow provides flexibility for credit unions to establish the methodology they choose and configure the options they want to include. The QCash Financial platform also provides an all-in-one system for required documentation.

Although the new rule doesn’t impact QCash, the financial platform supports all applicable CFPB requirements. Credit unions have the assurance that QCash provides everything needed to continue to offer compliant, short-term, small-dollar loans to its members.

May 17, 2018

by Ben Morales, QCash CEO

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Will My Credit Union Maintain CFPB Compliance with the QCash Short-Term, Small Dollar Lending Platform?

If you are a Credit union interested in the QCash, short-term, small-dollar lending program, and want to make sure that you are meeting CFPB compliance or meeting Consumer Financial Protection Bureau (CFPB) regulations – this post is for you.

Here are the three requirements for the QCash short-term, small-dollar lending program to maintain CFPB compliance:

  1. Loans may not have an interest rate of more than 36%
  2. Payment terms must be at least 45 days or more
  3. Disclosures must adhere to the Truth in Lending Act (TILA)

QCash also provides the following assurances:

As a short-term, small-dollar lending program, QCash maintains ongoing compliance with CFPB regulations.

QCash ensures compliance by utilizing the necessary resources and staying aligned with compliance regulations.

QCash provides web-based features like TILA documentation and e-Signature capability.

With QCash, credit unions have immediate access to all TILA documentation to upload and print as required to provide borrowers. CFPB ComplianceThe built-in e-Signature feature provides an extra layer of security to protect members’ transactions, keeping private information and digital data safe.

QCash allows credit unions to offer short-term, small-dollar loans to military members and stay in compliance with CFPB regulations.

QCash provides credit unions the ability to offer loans to military members, increasing the service level for this important market segment.

Automated payment schedule

QCash initiates and automates a repayment schedule when the loan is funded, eliminating extra steps for the credit union and delivering members the convenience of automated payments.

QCash is CFPB compliant with its automated repayment processes and technology.

The QCash automated repayment process and technology for member loans is CFPB regulation compliant.

QCash technology and methodology follows CFPB regulations.

The QCash short-term, small-dollar lending platform technology and methodology are CFPB compliant.

May 7, 2018

by Heidi Tinsley, QCash Director of Client Success

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