The settlement, filed as a stipulated final judgment on July 22, 2025, resolves a November 2021 CFPB lawsuit alleging that FirstCash violated the Military Lending Act since October 2016. The Fort Worth-based company operates over 1,000 retail pawnshops across the United States through wholly owned subsidiaries. Under the agreement, FirstCash must set aside $5 million for consumer redress and pay a $4 million civil penalty to the CFPB's victims relief fund.
The CFPB alleged that FirstCash made pawn loans to military borrowers covered under the MLA with annual percentage rates exceeding the law's 36% cap. The agency also alleged that loan agreements with covered borrowers violated the MLA by requiring arbitration for disputes and failing to provide mandatory disclosures. The MLA provides specific protections for active duty servicemembers and certain dependents when obtaining consumer credit.
Under the settlement terms, FirstCash must provide full redress to harmed servicemembers and their families in connection with thousands of allegedly unlawful pawn loans. The company must also comply with the MLA going forward and either offer MLA-compliant loan products to military families or implement regulatory safe harbors designed to screen for MLA-protected borrowers. The $4 million penalty goes to the CFPB's victims relief fund for consumer compensation.
The case stems from broader CFPB enforcement efforts targeting Military Lending Act violations across the financial services industry. The settlement also resolves alleged violations of a 2013 Bureau order against Cash America International, Inc., a predecessor entity to FirstCash. Following this settlement, the CFPB terminated the 2013 consent order on July 22, 2025, noting that the predecessor entity had fulfilled its obligations, including paying a $5 million civil penalty and providing consumer redress.
The settlement reflects the CFPB's continued focus on protecting military families from predatory lending practices. Military lending violations have been a priority enforcement area for the Bureau, which has brought numerous cases against companies that charge servicemembers excessive rates or fail to provide required protections under federal law.
The stipulated judgment represents a final resolution of the litigation, with the court entering the proposed order the same day it was filed. For practitioners, the case underscores the importance of implementing robust compliance programs for companies serving military customers and the significant financial penalties that can result from MLA violations.