Enova International, Inc.
On November 15, 2023, the Bureau issued an order against Enova International, Inc., a publicly-traded online small-dollar lender, headquartered in Chicago, Illinois, that markets, provides, and services loans under the brand names CashNetUSA (CNU) and NetCredit. In 2019, the Bureau issued an order against Enova based on the Bureau’s finding that Enova violated the Consumer Financial Protection Act of 2010 (CFPA) by debiting consumers’ bank accounts without authorization and failing to honor loan extensions it granted to consumers. The 2019 order, among other requirements, barred Enova from making or initiating electronic fund transfers without valid authorization and from failing to honor loan extensions. The Bureau found that Enova violated the 2019 Order, and therefore the CFPA, by debiting or attempting to debit consumers’ bank accounts in a wide array of circumstances without the consumer’s express informed consent; failing to honor loan extensions it had granted to consumers; debiting the full loan payment instead of a loan extension fee on loans for which Enova had granted a loan extension; and making or initiating electronic fund transfers from consumers’ bank accounts on a recurring basis without valid authorization identifying the particular bank account the consumer had authorized for EFTs and providing a copy of that authorization to the consumer. The Bureau also found that Enova violated the CFPA’s prohibition on unfair acts and practices by debiting or attempting to debit consumers’ accounts without their authorization and by canceling previously-granted loan extensions and debiting such consumers’ bank accounts for the full loan payment instead of a loan extension fee. The Bureau further found that Enova violated the CFPA’s prohibition on deceptive acts or practices by failing to tell consumers who had been granted a loan extension that making an interim partial payment would result in cancellation of the loan extension, misrepresenting the amount that Enova would charge consumers who made such an interim partial payment, misrepresenting the due date for certain loan payments, misrepresenting that consumers could skip certain loan payments, and misrepresenting the amounts due on certain consumer loans. The order bans Enova from offering or providing certain types of loans, requires Enova to come into compliance with the law, and requires Enova to incorporate compliance into its executive compensation policies and agreements. The order requires Enova to provide redress to all consumers whose accounts it debited without their express informed consent and to pay a $15 million civil money penalty.