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COMMITMENTS AND CONTENGENCIES
9 Months Ended
Sep. 30, 2021
Commitments and Contingencies Disclosure [Abstract]  
COMMITMENTS AND CONTENGENCIES COMMITMENTS AND CONTINGENCIES
Securities Litigation and Enforcement

In 2018, a putative securities fraud class action lawsuit was filed against the Company and certain of its officers and directors and other related parties in the United States District Court for the District of Kansas, captioned Yellowdog Partners, LP v. CURO Group Holdings Corp., Donald F. Gayhardt, William Baker and Roger W. Dean, Civil Action No. 18-2662 (the "Yellowdog Action"). The suit alleged the Company made misleading statements and omitted material information regarding the Company's efforts to transition the Canadian inventory of products from Installment loans to Revolving LOC loans.

On December 18, 2020, the Court granted final approval of a $9.0 million settlement and dismissed the case with prejudice. The Company's directors' and officers' insurance policy required the Company to pay the first $2.5 million in fees and settlement and the insurance carriers paid the remaining amounts. For the three and nine months ended September 30, 2021, there was no further expense related to the litigation.

In June and July 2020, three shareholder derivative lawsuits were filed in the United States District Court for the District of Delaware against the Company, certain of its directors and officers, and in two of the three lawsuits, a large stockholder. Plaintiffs generally allege the same underlying facts of the Yellowdog Action. In July 2021, the derivative lawsuits were voluntarily dismissed and Plaintiffs refiled two cases in the United States District Court for the District of Kansas. While the Company is vigorously contesting these derivative lawsuits, it cannot determine the timing or nature of their ultimate resolution. The Company does not expect that these derivative lawsuits will have a material adverse impact on the Company's results of operations or financial condition.

City of Austin

The Company was cited in July 2016 by the City of Austin, Texas for alleged violations of an Austin ordinance addressing products offered by CSOs, which regulates aspects of products offered under the Company's CAB program. The Company believes that: (i) the Austin ordinance (similar to its counterparts elsewhere in Texas) conflicts with Texas state law and (ii) in any event, the Company's product complies with this ordinance, when the ordinance is properly construed. In 2017, the Austin Municipal Court agreed with the Company's position that this ordinance conflicts with Texas law and, accordingly, did not address the second argument. In September 2017, the Travis County Court reversed the Municipal Court’s decision and remanded the case for further proceedings. To date, a hearing and trial on the merits have not been scheduled.

On May 15, 2020, the City of Austin proposed a second ordinance that became effective June 1, 2020, and implemented restrictions on CSO transactions and revised certain definitions included in the original Austin ordinance. These revisions potentially affect the foundation upon which the Company's previous arguments in municipal court were based.

The City of Austin notified the Company that it would begin auditing stores beginning in January 2021. In addition, the Company created and launched a new product during the second quarter of 2021. The city has since deferred these audits, and the Company is in discussions with the City to determine a potential resolution to the outstanding matters.

On January 27, 2021, the City of Dallas adopted an ordinance identical to the second ordinance in the City of Austin.

Given the change that the Company has made in its products in response to these ordinances, the Company does not anticipate that the CAB program’s past operations will result in material monetary liability in Austin or elsewhere in Texas at this time.

Delisle and Kato Class Action Lawsuits

In August of 2018, a class action lawsuit, Delisle v. Speedy Cash, was filed against Speedy Cash, a wholly-owned subsidiary of the Company, in the Southern District of California. The complaint alleged that Speedy Cash charged unconscionable interest rates on loans of $2,500 or above, in violation of consumer protection statutes, and sought restitution and public injunctive relief. In October 2018, Speedy Cash filed a motion to compel arbitration and stay proceedings. The District Court denied the motion. On July 2, 2021, the California District Court granted the parties’ joint motion to dismiss and the case was dismissed in its entirety with prejudice as to Plaintiffs’ individual claims and without prejudice as to the claims of the putative class members.

On September 3, 2021, a putative class action lawsuit, Kato v. Speedy Cash, was filed against Speedy Cash in the Superior Court of Los Angeles County, alleging similar facts as in Delisle. On October 14th, 2021, the case was removed to the United States District Court for the Central District of California. While Speedy Cash is vigorously contesting this lawsuit, it is too early to determine the final outcome, when it will be resolved, or whether it may be material.
2017 and 2020 CFPB Final Payday, Vehicle Title and Certain High-Cost Loans Rules (collectively, the "CFPB Rules")
The payment provisions of the CFPB Rules apply to short-term consumer loans (i.e., loans with terms of 45 days or less), longer-term balloon payment loans (i.e., any payments more than twice the size of other payments) and to longer-term loans with (i) annual percentage rates exceeding 36% and (ii) lender access to the consumer’s account, whether by ACH, card payment, check or otherwise (i.e., a “leveraged payment mechanism”). The payment provisions of the CFPB Rules generally prohibit lenders from seeking payment, without explicit borrower reauthorization, when two consecutive payments have failed due to insufficient funds; and, also require a series of prescribed notices for initial payments and “unusual” payments (e.g., amount, payment date or payment modality), and a consumer rights notice after two consecutive payment attempts have failed due to insufficient funds.

The 2017 Final CFPB Rule was originally scheduled to go into effect by August 2019. However, in April 2018, the CFSA and the Consumer Service Alliance of Texas, two industry trade groups (collectively, “Plaintiffs”), brought a lawsuit against the CFPB in a federal district court in Texas which resulted in a court-ordered stay of the CFPB Rules. In August 2020, both the Plaintiffs and the CFPB agreed to a briefing schedule related to their cross-motions for summary judgment. On August 31, 2021, the U.S. District Court granted the CFPB’s motion for summary judgment and denied the Plaintiffs’ motion for summary judgment, and ordered compliance with the CFPB Rules 286 days from the date of the Order.

Following the Court’s August 31, 2021 Order, Plaintiffs filed a Notice of Appeal with the Fifth Circuit. Plaintiffs also filed a Motion for Stay Pending Appeal, asking to stay the compliance date until after their appeal is fully and finally resolved. On October 14, 2021, in its unanimous decision, the Fifth Circuit granted the motion by Plaintiffs to extend the compliance date until 286 days after resolution of their appeal.

We cannot provide assurance that Plaintiffs will prevail at the appellate level. In the event Plaintiffs are unsuccessful at the appellate level, compliance with the payment provisions of the CFPB Rules would require significant modifications to our payment, customer notification and compliance systems and will create delays in initiating consumer-authorized automated collection attempts when payments we initiate are unsuccessful. These modifications would increase the Company’s costs and reduce revenues. Accordingly, unless the payment provisions are declared invalid, they may have a material adverse effect on our results of operations.

Other Legal Matters
The Company is a defendant in certain other litigation matters encountered from time-to-time in the ordinary course of business, some of which may be covered to an extent by insurance. While it is difficult to predict the outcome of any particular proceeding, the Company does not believe the result of any of these matters will have a material adverse effect on the Company's business, results of operations or financial condition.