On April 14, the CFPB along with the Navajo Nation jointly announced an enforcement action against two companies and their respective owners (Defendants) for running an alleged tax-refund scheme, marking the CFPB’s “first enforcement action taken in conjunction with a tribal government.” According to the complaint, the Defendants operated several tax-refund franchises in New Mexico and in the Navajo Nation territory in which clients were offered short-term, triple-digit APR loans secured by the consumer’s anticipated tax refund, also known as refund anticipation loans (“RALs”). The CFPB and Navajo Nation contend, among other things, that the Defendants (i) steered low-income and vulnerable consumers toward high-cost RALs; (ii) understated the APR of the RALs in disclosure agreements to consumers; and (iii) failed “to disclose that consumers’ tax refunds had been received and would soon be available, but instead persuaded consumers to take out additional RALs.” Under the terms of the proposed consent order, the Defendants would, among other things, (i) pay approximately $438,000 in total consumer redress, which consists of $256,267 in redress fees in addition to roughly $184,000 that has already been paid to affected consumers; (ii) incur $438,000 in civil money penalties; and (iii) be barred, for five years, from offering products associated with tax refunds. The consent order also would prohibit the Defendants from investing, financing, or working for an entity that offers tax refund products.