Banking and Finance Law Daily Wrap Up, ENFORCEMENT ACTIONS—CFPB announces $9 million settlement with FirstCash, Inc., (Jul 14, 2025)
Law Firms Mentioned:Alston & Bird LLP
Organizations Mentioned:Alston & Bird, LLP | Cash America Advance, Inc. | Cash America East, Inc. | Cash America Inc. of Alaska | Cash America Pawn L.P. | Cash America Pawn, LP | Cash America West, Inc. | Cash America of Missouri, Inc. | Cash America, Inc. of Alaska | Cash America, Inc. of Louisiana | Cash America, Inc. of North Carolina | Consumer Financial Protection Bureau | FCFS AL, Inc. | FCFS IN, Inc. | FCFS KY, Inc. | FCFS MO, Inc. | FCFS NC, Inc. | FCFS OH, Inc. | FCFS OK, Inc. | FCFS SC, Inc. | FCFS TN, Inc. | First Cash Financial Services, Inc. | FirstCash, Inc. | Georgia Cash America, Inc. | Pawn TX, Inc.
By Joe Cox, J.D.
The settlement of a 2021 suit for alleged for Military Lending Act violations includes a $4 million fine and $5 million ear-marked for restitution.
The Consumer Financial Protection Bureau announced the settlement of a 2021 enforcement action filed against FirstCash, Inc., and nineteen subsidiaries. FirstCash was established in Delaware and is headquartered in Texas. FirstCash owns and operates over 1,000 pawn shops in the United States.
The action was filed in Texas federal district court over alleged violations of the Military Lending Act (see Banking and Finance Law Daily, Nov. 15, 2021). The CFPB claimed that since 2016, FirstCash had made pawn loans to borrowers covered under the MLA with rates that exceeded the MLA’s maximum allowable annual percentage rate of 36 percent. The suit also alleged legal violations in requiring arbitration and failing to make all required disclosures regarding loans. In addition, the CFPB charged that these MLA violations were also violations of a 2013 order against a predecessor entity. FirstCash and its affiliates neither admitted or denied the various allegations asserted by the CFPB, except to the extent necessary to establish jurisdiction over the matter.
Settlement terms. The proposed order would require FirstCash and affiliates to set aside $5 million for restitution to impacted consumers from the implicated pawn loans. Additionally, the company would be required to pay a $4 million fine to the CFPB Victim Relief Fund. Finally, FirstCash would also have to comply with the MLA moving ahead and either offer a compliant loan product to servicemembers or comply with a regulatory safe harbor meant to screen for MLA-protected borrowers.
Over 42,000 pawn loans have been flagged by the CFPB and the restitution terms will mandate that FirstCash pay 120 percent of the interest, fees, and non-principal charges paid by the impacted consumers. Additional reporting requirements have also been imposed on FirstCash moving forward.
Attorneys: Jacob Alden Schunk for the CFPB. Michael John Agoglia (Alston & Bird LLP) for FirstCash, Inc., Cash America West, Inc., FCFS AL, Inc., Cash America East, Inc., Cash America Inc. of Alaska, Georgia Cash America, Inc., FCFS IN, Inc., FCFS TN, Inc., FCFS OH, Inc., FCFS KY, Inc., Cash America, Inc. of Louisiana, FCFS MO, Inc., Cash America of Missouri, Inc., Cash America, Inc. of North Carolina, FCFS NC, Inc., FCFS OK, Inc., FCFS SC, Inc., Pawn TX, Inc., Cash America Pawn L.P. and Cash America Advance, Inc.
Companies: FirstCash, Inc.; Cash America West, Inc.; FCFS AL, Inc.; Cash America East, Inc.; Cash America Inc. of Alaska; Georgia Cash America, Inc.; FCFS IN, Inc.; FCFS TN, Inc.; FCFS OH, Inc.; FCFS KY, Inc.; Cash America, Inc. of Louisiana; FCFS MO, Inc.; Cash America of Missouri, Inc.; Cash America, Inc. of North Carolina; FCFS NC, Inc.; FCFS OK, Inc.; FCFS SC, Inc.; Pawn TX, Inc.; Cash America Pawn L.P.; Cash America Advance, Inc.
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