The CFPB announced the resolution of its November 12, 2021 lawsuit against FirstCash, a Delaware nonbank headquartered in Fort Worth, Texas, that operates more than 1,000 retail pawnshops in the United States through wholly owned corporate subsidiaries. The parties jointly filed a stipulated final judgment and proposed order, "which the court promptly entered the same day," according to the agency.
The bureau alleged that since October 3, 2016, FirstCash and its subsidiaries made pawn loans to borrowers covered by the Military Lending Act at annual percentage rates exceeding the statute's 36% cap. The CFPB also alleged the loan agreements with covered borrowers required arbitration in the case of a dispute and failed to include all mandatory loan disclosures.
Under the order, the defendants must set aside $5 million "to ensure full redress to harmed servicemembers and their family members in connection with thousands of unlawful pawn loans," the agency said. The defendants must also pay a $4 million fine to the CFPB's victims relief fund.
The order further requires FirstCash to comply with the MLA going forward, and to either "offer an MLA-compliant loan product to servicemembers and their families" or "comply with a regulatory safe harbor meant to screen for MLA-protected borrowers."
The CFPB said the alleged conduct also violated a 2013 bureau order against Cash America International Inc., a FirstCash predecessor. According to the agency, it terminated the 2013 consent order on July 22, 2025, because Cash America had fulfilled its obligations under that order, including paying a $5 million civil money penalty and providing consumer redress. "The predecessor entity no longer exists and the products addressed in the 2013 order are unconnected to the products of FirstCash," the bureau said.
The MLA caps covered consumer credit to active duty servicemembers and certain dependents at a 36% annual percentage rate, prohibits required arbitration clauses, and mandates specified loan disclosures.