There is no claim form here, and there is no way to ask to be included. The FirstCash military lending redress is a government enforcement order, not a class action: the CFPB and FirstCash identify eligible borrowers from FirstCash’s own loan data, and a check goes out automatically. Paragraph 20 of the order makes that process exclusive. A servicemember who believes they qualify but never receives a notice has no application to file.
Status: Payments pending | No claim form, no deadline | $5,000,000 consumer redress, plus a separate $4,000,000 civil penalty
This Is Not a Class Action
The distinction matters for every practical question a borrower has.
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 fairness hearing, no opt-out decision, no objection window, and no claim deadline — because none of those mechanisms exist in a Consumer Financial Protection Bureau enforcement action.
What that buys a consumer is simplicity: payments are automatic, and a paper check is mailed to anyone who does nothing. What it costs them is the one route a class action always provides — the ability to step forward and say I belong in this.
What the CFPB Alleged
The Bureau sued FirstCash, Inc. and nineteen affiliated pawn companies on November 12, 2021 and filed an amended complaint on June 21, 2022. It 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.
Who Counts as an Affected Consumer
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 MAPR above 36%, a mandatory arbitration provision, or disclosures that fell short of the MLA’s requirements including the required MAPR statement.
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.
Paragraph 20 Is the Part Nobody Reads
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 also 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.
Two Formulas, and Redemption Decides Which
| 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 under 12 U.S.C. § 5497(d); it is not divided among the servicemembers in this case.
The Payment Election Form Does Not Gate Any Money
Because there is no claim form, there is no proof to submit and no documentation to gather. 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 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.
Is There a 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.
Three Things Worth Doing Anyway
- Confirm the mailing address on file. 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 you want an electronic payment, 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 know 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 administrator’s FAQ says the eligibility determination is still running and directs consumers to watch the official settlement website. No payment date has been announced.
The Conduct Provisions Run Alongside the Money
For five years FirstCash may not extend MLA-violative loans to covered borrowers. 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.
Frequently Asked 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. Eligibility arrives as a mailed notice or it does not arrive at all.
Which lenders are covered?
FirstCash, Inc. and its nineteen co-defendant pawn companies, which trade under the Cash America and FCFS names across more than 1,000 U.S. pawn stores. The qualifying loan had to be taken out between October 3, 2016 and January 11, 2026 while the borrower met the Military Lending Act definition of a covered member, dependent or covered borrower.
How much does the FirstCash redress pay?
It depends on whether the pawned item was redeemed. If the collateral was redeemed, the payment is 120% of all fees, interest and other charges paid on each non-compliant loan, with principal excluded. If the collateral was not redeemed, it is all fees, interest and other charges paid plus an additional amount equal to the full principal. Both figures are per loan, so a borrower with several qualifying transactions is paid on each.
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. section 5497(d). Consumer redress in this case comes from the separate $5 million redress account, and that $5 million is a floor rather than a cap – the order requires FirstCash to deposit more if the calculated total runs higher.
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 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. The Bureau and FirstCash are still working through the loan-by-loan identification process the order sets out.
Sources
- 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.
- 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.
- OpenClassActions.com — FirstCash $5M Military Lending Act Settlement.
Source and credit: the settlement terms, deadlines and benefit tiers described above are drawn from our sister site’s reporting — OpenClassActions.com: FirstCash $5M Military Lending Act Settlement — which tracks this case against the court-approved notice and the official settlement website and is updated as the court rules.
Legal Disclaimer
This article is for informational purposes only and is not legal advice. OpenClassActions.org is a consumer news site, not a law firm and not the settlement administrator, and is not affiliated with any party to the case described. The allegations are allegations; the defendants deny wrongdoing and no court has decided the merits. Deadlines, benefit amounts and payment timing can change as the court and the administrator act, so confirm current status on the official settlement website. You never need to pay anyone to file a claim or to receive a settlement payment.