Amicus Brief Against Delay of Payday Rule Compliance Date
On May 31, 2018, the parties to this action filed a joint motion asking the Court to stay both this litigation and the principal compliance date of the Consumer Financial Protection Bureau (CFPB)’s regulation on payday, vehicle title, and certain high-cost installment loans, 12 C.F.R. part 1041 (“Payday Rule”), at issue in the case. In support of their request for a stay of the rule’s compliance date, the parties rely on the Administrative Procedure Act (APA), 5 U.S.C. § 705. Because section 705 does not authorize a stay in the circumstances of this case and because the Court lacks adversarial...