| Member Login | Edit Your Profile I Logout    



About Us

Our Mission

Code of Ethics





For Members

CFL News


Join Us


Gray Buttons Above Are For Members Only


"For Lenders You Can Trust Look For The Borrow Smart Seal."






Monday, February 6, 2012


We continue to learn more regarding the CFPB and their plans for the short term lending industry as noted below.  The focus is payday lending at the moment but clearly all lenders will be under the microscope in the short to intermediate term for full compliance with all federal laws as seen in the CFPB field examination manual here.  And then over the course of the next six to nine months we can expect new regulations to be promulgated by the CFPB that will increase the intensity.

The message from our industry leaders in Washington is to expect changes.  Big changes. Compliance exams will be quite extensive.  A national law firm that focuses on the new CFPB is Ballard Spahr and they have published recent articles regarding exam expectations and what this means for the industry.  Click here for their opinion on what you can expect in an examination and click here to read their discussion about the "remittance transfer" rule to see how complex something as simple as an electronic transfer to a foreign country transaction will become.

We strongly believe the compliance area of the CFPB will be significant for all operators.  We are in the very early stages of developing a solution for association members.  Stay tuned. 

Friday, January 30, 201


The video on the right is an abbreviated version of the full interview with Director Cordray that occurred on Meet The Press on January 29th (full interview below).  Note a few of the Director's comments:

  • Immediate enforcement

  • Tough questions of industry

  • Sustainability of customers

  • Enforcement action

Director Cordray used many of these same comments at the hearing in Birmingham on January 19th.  There should be absolutely no doubt whatsoever of the CFPB's plans and intentions.  We believe their focus will be on enforcement of a myriad of quite complex federal laws that most in the industry have not previously focused on and on repeat transactions of single payment loans.

While Mr. Cordray's remarks yesterday on Meet The Press addressed payday lenders only one time during the interview, don't take any comfort that our industry is not in the CFPB's crosshairs.  Do not forget, the very first public action the CFPB took was against our industry (scroll down).  And remember, when they came to Birmingham on January 19th they met privately with many interest groups (activist, credit unions, etc.).  They did not, however, meet privately with any industry groups or with our own state regulators.  So, we believe their focus is against our industry and it will be a federal effort as succinctly outlined by Mr. Cordray on the two last occasions we have seen him.

Our local associations are working hard to prepare for major and significant changes in the way we do business.  If you are a member login above and click here or the CFL News tab on the left for an assessment of what we expect and discussion of plans.  You will need your member login to access the member section of the web site.



Visit msnbc.com for breaking news, world news, and news about the economy

Friday, January 19, 2012 -- 5:45 PM


The CFPB hearing today, for the most part, went as expected.  This was a consumer event and you can pretty well imagine how the comments and testimony unfolded even though the industry was well represented..  You should expect to see fairly vigorous national reporting on this event.

The CFPB has a website and it is updated often (here).  The remarks from yesterdays meeting will be on the web site soon.  You will also find the CFPB field examination manual here.

If you are a member of Borrow Smart you can click here and go to our member section for a more detailed report on today's meeting.

Wednesday, January 18, 2012 -- 4:00 PM

This is an update to the post below made on January 16 and will provide you with the very latest information that we have on the hearing tomorrow.  Here are a few comments:

1) The venue for the meeting has changed.  The new venue will accommodate a much larger crowd.  However, we have no clue how many will be allowed to attend.  The same is true for those who did not register -- we don't know if you will be allowed into the room if you did not register.  The CFPB notice document requested that people register as you see in this latest notice (click here).  We have heard reports that the registration system no longer works.  That is all we know at the moment.

2) We have a special member update for TPCA and Borrow Smart members regarding more information about attendance and what you can expect. CLICK HERE FOR THAT ADDITIONAL INFORMATION.  You will need a member login and you will need to navigate back to this page after you have logged in.  If you are a member (TPCA or Borrow Smart AL) or a guest and do not have a login follow the steps to register as instructed in the links at the top of this page.  We will review your request and respond back promptly.

As soon as we know more that we can share we will be in touch.  Otherwise, we will update again on Friday.

January 16, 2012


We urgently need your help in locating customers who can attend this hearing which is set for this Thursday, January 19th in Birmingham.  If you can help click here for instructions and contact information from the CFSA who is coordinating this effort.  Please work hard on this request it is important.

Read the story below for more information regarding this event.

CFPB TO HOLD HEARINGS IN BIRMINGHAM.  January, 16, 2011.   The new CFPB (Consumer Financial Protection Bureau), which only recently named their new director with a controversial appointment, is now set to begin their regulating effort.  The have set a field hearing for this coming Thursday, January 19 in Birmingham.  Click here to see the notice.  It is noteworthy they selected Birmingham as the venue for this first ever field hearing.  It is noteworthy on two accounts.  First, Birmingham is noted as a birthplace for the civil rights movement (the hearing is being held at the Civil Rights Museum) and second, we recently went through an extended battle over a moratorium against short term lending (click here) in Birmingham.

The big question is -- what is the impact?  The answer is -- no one knows.  The announcement was made last Thursday in the press.  Borrow Smart is working closely with the CFSA to coordinate attendance and media at the hearing.  The CFSA has developed a relationship with the CFPB but the CFSA has not published a public statement yet. 

It will be after the hearings before we have more information.  At a minimum, we believe this may mark the beginnings of the CFPB's regulatory effort.  But beyond that we do not know.  We will report back after the hearing with more information.



Privacy Notice I Website Disclaimer | Web Site By: The Genesis Group