Servicemembers and military dependents who took out a pawn loan from FirstCash or one of its Cash America subsidiaries between October 3, 2016 and January 11, 2026 may be paid automatically from a $5 million CFPB redress fund; there is no claim form to file. The Bureau and FirstCash are still identifying who qualifies, and no payment date has been announced.
Current Status
There is no claim form and no claim deadline. Payments are automatic for consumers the Consumer Financial Protection Bureau and FirstCash identify as eligible, and a paper check is mailed to anyone who does nothing.
Judge Mark T. Pittman entered the Stipulated Final Judgment and Order on July 11, 2025 in the U.S. District Court for the Northern District of Texas, which is the settlement's Effective Date. The order is final; there is no separate class action fairness hearing, because this is a government enforcement action rather than a class action.
The settlement administrator's FAQ says the eligibility determination is still running and directs consumers to watch the official settlement website. No payment date had been announced as of September 8, 2026.
What Changed Recently?
The CFPB sued FirstCash, Inc. and nineteen affiliated pawn companies on November 12, 2021 and filed an amended complaint on June 21, 2022. The Bureau alleged that since October 3, 2016 the companies issued pawn loans to servicemembers and their dependents at a Military Annual Percentage Rate above the Military Lending Act's 36% cap, embedded mandatory arbitration provisions the MLA prohibits, and omitted disclosures the statute requires, including the written and oral statement of the MAPR.
The parties resolved the case on July 11, 2025 with a stipulated order the court entered the same day. FirstCash neither admits nor denies the allegations, apart from the facts establishing the court's jurisdiction, and the order was entered without any adjudication of fact or law. No court has found the companies liable.
The order set aside $5 million for consumer redress and imposed a separate $4 million civil money penalty. On July 22, 2025 the Bureau also terminated a 2013 consent order against Cash America International, a FirstCash predecessor, on the ground that the predecessor had satisfied its obligations under it.
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Who Qualifies?
The order defines an Affected Consumer as someone who, between October 3, 2016 and six months after the Effective Date, met the Military Lending Act definition of a covered member, dependent or covered borrower, and who took out a pawn loan from the defendants while covered, where that loan carried at least one of three defects:
- a Military Annual Percentage Rate above 36%;
- a mandatory arbitration provision; or
- disclosures that fell short of the MLA's requirements, including the required statement of the loan's MAPR.
The Effective Date is July 11, 2025, which puts the end of that window at January 11, 2026. The lenders covered are FirstCash, Inc. and its nineteen co-defendants, which trade under the Cash America and FCFS names across more than 1,000 U.S. pawn stores.
One limitation matters more than the class period. Paragraph 20 of the order makes the identification process exclusive: the Bureau and FirstCash agree on the population from FirstCash's own loan transaction data, and the Bureau had already flagged 42,698 pawn loans covering October 3, 2016 through August 25, 2024, with two later data productions covering the periods after that. A borrower cannot apply, nominate themselves, or add a loan to the list. Eligibility arrives as a mailed notice or it does not arrive at all.
Note that 42,698 is a count of loans, not of people. One borrower with several pawn transactions appears more than once, so the number of consumers due redress is smaller than the loan count.
How Much Can You Get?
The order sets two formulas, and which one applies turns on whether the borrower got their pawned item back.
- Collateral redeemed: 120% of all fees, interest and other charges paid on each non-compliant pawn loan. Principal is excluded, because the borrower recovered the item.
- Collateral not redeemed: all fees, interest and other charges paid, plus an additional amount equal to the full principal of each non-compliant loan.
Both figures are per loan, so a borrower with several qualifying pawn transactions is paid on each. Amounts a borrower already got back are offset — if FirstCash previously refunded the same fees or principal, that is deducted, though a borrower who redeemed and received less than the 120% figure is topped up to it.
The $5 million reserve is a floor rather than a cap. The order requires FirstCash to deposit more if the calculated total runs higher, to keep the account from falling below what is owed, and to pay every Affected Consumer regardless of whether the total exceeds $5 million. If the total comes in under $5 million, FirstCash recovers the difference.
The separate $4 million civil money penalty is not part of this. It goes to the Bureau and is deposited in the Civil Penalty Fund; it is not divided among the servicemembers in this case.
What Proof or Notice ID Is Required?
Nothing is required to be paid. Because there is no claim form, there is no proof to submit and no documentation to gather, and the payment arrives whether or not a consumer ever visits the settlement website.
The Unique ID and PIN printed on the mailed notice are needed only to log into the Payment Election Form. That form does not gate any money. It exists so an eligible consumer can take payment as a virtual prepaid card, PayPal, Venmo or Zelle instead of a paper check, or correct an address the administrator has wrong. Skipping it means a check in the mail, which is the default.
Anyone who has misplaced their notice can request the Unique ID and PIN through the contact channels listed on the official settlement website by providing their full name and mailing address.
What Is the Deadline?
There is no claim deadline, because there is no claim. The stipulated order sets none, and the administrator's published FAQ states none.
The Payment Election Form may carry its own cutoff, since an election has to be recorded before the administrator issues payment. That date is not stated in the order or in the FAQ, so anyone who wants an electronic payment rather than a check should check the official settlement website for the operative date rather than assume one. Missing it is not a forfeiture: the consequence is a paper check instead of a digital payment.
How Do You Take Action?
For most eligible consumers the answer is to do nothing and watch the mail. Three things are worth doing anyway:
- Confirm the mailing address on file, since the entire redress mechanism is a check sent to the address the administrator has. A consumer who moved since their last FirstCash pawn transaction is the one most likely to lose a payment.
- Submit the Payment Election Form only if an electronic payment is preferred, using the Unique ID and PIN from the notice at the official FirstCash settlement website.
- Treat any message asking for a Social Security number, a bank login or a fee as a red flag. The real process asks for none of those, and the administrator is Simpluris.
Consumers who believe they were a covered borrower but receive nothing should note that the order gives them no route to add themselves to the redress population. The CFPB does accept consumer complaints, and the order requires FirstCash to remain registered on the Bureau's Company Portal and to disclose on its consumer-facing websites that consumers can file one.
What Happens Next?
The Bureau and FirstCash are still working through paragraph 20. FirstCash had 30 days from the Effective Date to object to loans on the Bureau's initial list, with a good-faith negotiation process and an in-person meeting if the two sides deadlocked, and the same objection cycle repeats for the two later data periods. The court kept jurisdiction to resolve disputes over that process and may order the parties to mediation.
Once the population is settled, FirstCash pays under a redress plan the Bureau has already given non-objection to. Within 30 days of finishing, FirstCash must file a Redress Report giving the number of consumers paid, the total paid and their states of residence. Five years after the Effective Date any balance left in the redress account goes to the Bureau, which may use it for further redress or deposit it in the U.S. Treasury.
The conduct provisions run alongside the money. For five years FirstCash may not extend MLA-violative loans to covered borrowers, and from January 2026 through January 2031 it must either use the Department of Defense safe harbor for every pawn transaction or advertise and offer an MLA-compliant pawn product, screened by a scripted point-of-sale intake the order reproduces in full.
Sources and Verification
- Stipulated Final Judgment and Order, Consumer Financial Protection Bureau v. FirstCash, Inc., et al., No. 4:21-cv-01251-P (N.D. Tex. July 11, 2025), Document 134 — embedded below.
- CFPB newsroom release, "CFPB Reaches Settlement with FirstCash, Inc. and Its Subsidiaries for Military Lending Act Violations" (July 11, 2025, updated July 22, 2025).
- CFPB enforcement action page, FirstCash, Inc. and Cash America West, Inc.
- Official settlement website and administrator FAQ, administered by Simpluris.
Questions
Is there a claim form to file for the FirstCash settlement?
No. The settlement administrator's FAQ states that consumers determined eligible for a payment do not need to submit a Payment Election Form. Anyone who submits nothing is mailed a paper check at the address the administrator has on file.
Can I apply to be included in the FirstCash redress population?
No. Paragraph 20 of the Stipulated Final Judgment and Order makes the CFPB and FirstCash the exclusive route to identifying affected consumers, working from FirstCash loan transaction data. There is no application, and nothing a borrower submits adds them to the list.
Does the $4 million civil penalty get paid to servicemembers?
No. The $4 million civil money penalty is paid to the CFPB and deposited in the Bureau's Civil Penalty Fund under 12 U.S.C. § 5497(d). Consumer redress in this case comes from the separate $5 million redress account.
What is the Payment Election Form for?
It lets an eligible consumer take payment as a virtual prepaid card, PayPal, Venmo or Zelle instead of a paper check, and lets them correct an address. Logging in requires the Unique ID and PIN printed on the mailed notice. It is optional, and it is not an application for payment.
When will FirstCash settlement payments be sent?
No payment date has been announced. The administrator's FAQ says the process of determining who is eligible is ongoing and directs consumers to check the official settlement website for updates.
