Section 1414 of the Dodd-Frank Act amended the Truth in Lending Act (TILA) to prohibit lenders from financing credit life insurance, with exceptions for insurance premiums “paid in full on a monthly basis” and for credit unemployment insurance (if other requirements are met). 15 USC 1639c(d). Section 1400 of Dodd-Frank states that these provisions will not become effective until “final regulations implementing such section, or provision, take effect.” Under a final rule delaying the effective date of the regulations implementing the credit insurance rules, the CFPB announced a January 10, 2014 effective date. 78 Fed. Reg. 32547, 32549 (May 31, 2013).