Banks and Credit Unions now have a better opportunity to ensure that they meet consumers’ needs for short-term, small-dollar loans. The CFPB has proposed to remove the underwriting provisions from the small-dollar (payday) lending rule it issued in October 2017. The rule imposes an ability-to-pay test on a wide range of small-dollar loans of 45 days or less, including payday loans, auto title loans and bank-provided loans with balloon payments. The CFPB’s proposal maintains the complete exemption in the rule for banks and other depository institutions that made 2,500 or fewer small-dollar loans in each of the current and previous years and for which these loans account for less than 10 percent of revenues. The CFPB is also proposing to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the 2017 final rule to November 19, 2020. The extension is intended to help lenders avoid expending unnecessary resources to comply with provisions that the CFPB has proposed to rescind. Comments on the proposal to delay the compliance date for the ATR provisions are due on or before March 18, 2019. Comments on the proposal to rescind the ATR provisions are due on or before May 15, 2019.