OLA Regulatory Affairs

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The Online Lenders Alliance works with regulatory agencies such as the CFPB, FDIC and FTC to provide input on how lending institutions are regulated and interact with consumers.

OLA helps its members stay informed of changes in regulations at the Federal and State levels to ensure compliance with regulatory guidelines, in addition to working with States’ Attorneys General on enforcement issues pertaining to the industry.

OLA members are briefed on the latest policies impacting the industry during bi-weekly Regulatory and Legislative calls, Daily News Clips, Weekly Newsletter and OLA Special Alerts. Keeping members informed ensures a healthy and viable future for our industry.

Please register and log in to your OLA member account to access all files.

Regulatory

Item Name	Posted By	Date Posted
U.S. Court of Appeals Decision on NLRB Appointment PDF (904.64 KB) [ more ] [ hide ]	Administration	5/16/2013
The U.S. Court of Appeals for the Third Circuit issued an opinion holding that a purported "recess” appointment to the National Labor Relations Board (NLRB) was invalid and unconstitutional. This decision echoes the earlier decision of the U.S. Court of Appeals for the District of Columbia Circuit in Noel Canning v. NLRB, and holds that the term "recess appointment” refers to an appointment which is made between sessions of Congress, and does not apply to appointments which are made during sessions of Congress. That is, the President may only make appointments without Senate approval during inter-session recesses, and not during an intra-session break in proceedings.
Assessing the Optimism of Payday Loan Borrowers PDF (354.49 KB) [ more ] [ hide ]	Administration	4/15/2013
In this article Ronald Mann of Columbia Law School, uses survey data to show that most consumers accurately anticipate when the loan will be repaid. Prof. Mann surveyed 1400 customers of a national payday lender in 5 states, and 60% of borrowers were able to predict when they would repay the loan within a 14-day window. That is, most consumers were not laboring under the illusion that they would repay the loan on the first due date, and they nonetheless chose to borrow.
Google AdWord Policy Changes PDF (2.09 MB)	Administration	2/21/2013
Small Business Administration Size Standards PDF (98.22 KB) [ more ] [ hide ]	Administration	11/13/2012
OLA comments to the Small Business Administration Size Standards (November 2012).
CFPB Annouces Supervisory Highlights PDF (172.93 KB)	Administration	10/31/2012
Examination Procedures for Debt Collection Link	Administration	10/29/2012
Final Debt Collection Rule Link [ more ] [ hide ]	Administration	10/29/2012
October 2012-The CFPB has released a final rule defining larger participants for the debt collection market. The CFPB will have supervisory authority over any firm with more than $10 million in annual receipts from consumer debt collection activities. The CFPB estimates this authority will apply to 175 debt collection firms, which collectively account for more than 60% of the debt collection industry’s total activities.
Debt Collection Fact Sheet Link	Administration	10/29/2012
OLA Comment Letter: Supervision of Risks PDF (42.12 KB)	Administration	10/15/2012
OLA Comment Letter: Consumer Complaint Disclosure PDF (43.62 KB)	Administration	10/15/2012
CFPB Organization Chart PDF (63.61 KB)	Administration	9/17/2012
FDIC Unbanked and Underbanked Executive Summary PDF (467.87 KB)	Administration	9/17/2012
2012 FDIC Unbanked and Underbanked Report PDF (7.77 MB)	Administration	9/17/2012
Cordray Testimony for House Small Business Hearing PDF (387.01 KB) [ more ] [ hide ]	Administration	8/4/2012
CFPB Director, Richard Cordray prepared testimony for the House Small Business Committee hearing entitled: “Know Before You Regulate: The Impact of CFPB Regulations on Small Businesses” from August 1, 2012
FCC Robocall Rulemaking Notice PDF (282.02 KB)	Administration	6/11/2012
Senate Letter to CFPB on GAO report- 2012 PDF (388.94 KB)	Administration	6/11/2012
2012 Survey on Credit Card Debt PDF (1.03 MB)	Administration	6/11/2012
GAO Report on CFPB Internal Controls Link	Administration	5/29/2012
CFPB Short-term examination procedures Link	Administration	3/9/2012

Submitted OLA Comment Letters

Item Name	Posted By	Date Posted
Policy to Encourage Trial Disclosure Programs PDF (52.99 KB) [ more ] [ hide ]	Administration	2/19/2013
OLA submitted a comment letter responding to the CFPB 's Proposed Trial Disclosure Policy. Although the letter addresses the Proposed Policy and makes recommendations for improvement, the focus is on APR and how APR is an ineffective and misleading measure of the cost of a short-term loan.
Small Business Administration Size Standards PDF (98.22 KB) [ more ] [ hide ]	Administration	11/15/2012
OLA comments to the Small Business Administration Size Standards (November 2012).
Supervision of Risks to Consumers PDF (42.12 KB)	Administration	8/4/2012
Larger Participant Rule PDF (54.12 KB) [ more ] [ hide ]	Administration	8/4/2012
The proposal would cover debt collectors with more than $10 million in annual receipts and credit bureaus with more than $7 million in annual receipts.

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Regulatory

Submitted OLA Comment Letters