Article X for the work produced the customer Financial Protection Bureau with plenary supervisory, enforcement and rulemaking authority pertaining to payday lenders. The work will not differentiate between tribal and non-tribal loan providers. TLEs, which will make loans to customers, autumn squarely in the concept of “covered people” beneath the work. Tribes aren’t expressly exempted through the conditions regarding the work if they play consumer-lending functionality.
The CFPB has asserted publicly it has authority to manage tribal payday lending
However, TLEs will argue that they certainly should not fall in the ambit regarding the work.