Hogan Lovells 2024 Election Impact and Congressional Outlook Report
15 November 2024
Recent regulatory developments of interest to financial institutions with focus on consumer finance. See also our Related Materials links for updates with broader application.
The Competition and Markets Authority (CMA) has published a template of a summary of borrowing statement, to be used by lenders to comply with obligations in the Payday Lending Market Investigation Order 2015 (the Order).
The Order, made following the payday lending market investigation, prohibits lenders from supplying payday loans unless customers are provided with a summary of the cost of borrowing. In addition, a summary of borrowing containing specific information must be delivered at specific time periods. The aim of these provisions is to ensure that customers are aware of the fees and charges associated with their loan product. These requirements were imposed because the CMA found that the information provided by lenders prior to the Order was insufficient and not clear enough to allow customers to make well informed decisions.
The template sets out the information that a payday lender must provide in the summary of borrowing statement. It is designed to help achieve consistency across both the information and format of information that payday lending customers receive, to make it easier for them to understand the products they use.
The Council of the EU has published a note from the General Secretariat to the Delegations with a three-column table to commence trialogues, comparing the negotiating positions taken by the European Commission, the Council and the European Parliament on the proposed Directive on credit servicers and credit purchasers.
Authored by Yvonne Clapham