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When does a borrower have to sign an identification statement for payday loans? – IBA Compliance Connection

When does a borrower have to sign an identification statement for payday loans?

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The borrower identification statement requirements apply to payday loans with terms of 91 days or fewer (and in which the amount financed does not exceed $2,000). 32 CFR 232.3(b)(1)(i). The bank should provide the “covered borrower identification statement” to each applicant “[p]rior to becoming obligated on the transaction.” 32 CFR 232.5(a)(1)

And, a covered borrower is defined as a “regular or reserve member” of the armed forces “serving on active duty under a call or order that does not specify a period of 30 days or fewer” (and spouses and children of such borrowers).  32 CFR 232.3(c).