TitleMax Lawsuits: CFPB Orders, Data Breach, and Pennsylvania Fine

TitleMax lawsuits over the past decade include two federal Consumer Financial Protection Bureau consent orders, a $12 million data breach class settlement, an active class action over illegal loans to military families, and a pending Pennsylvania enforcement action seeking $52.7 million in penalties. The auto title lender, operated by TMX Finance LLC out of Savannah, Georgia, has been penalized for deceptive lending, in-person debt collection at borrowers’ homes and workplaces, illegal high-rate loans to servicemembers, and a breach that exposed data on roughly 4.8 million people.

The 2016 CFPB Consent Order

The first major federal action landed on September 26, 2016, when the CFPB found that TMX Finance had engaged in unfair and abusive lending and debt collection practices. TitleMax had marketed a “Voluntary Payback Guide” for its 30-day loans that suggested a structured repayment plan without disclosing that the guide was not actually a plan and that repeated renewals would sharply increase the loan’s total cost. The Bureau also found that the company had revealed information about past-due debts to third parties during visits to borrowers’ homes and places of employment.¹

The consent order required TMX to pay a $9 million penalty and to stop the identified practices, including the in-person collection visits.¹ The Center for Responsible Lending noted at the time that TitleMax averaged eight loan renewals per customer.² The order was modified six times between June 2021 and February 2023 and is now listed as expired.

The 2023 CFPB Order on Military Lending

On February 23, 2023, the CFPB issued a second consent order. Between October 2016 and September 2021, TitleMax had issued at least 2,670 prohibited auto title loans to active-duty servicemembers and their dependents, often at interest rates above 100 percent — well over the Military Lending Act’s 36 percent cap. The Bureau alleged that TitleMax employees had doctored personally identifiable information to conceal borrowers’ protected military status.³ The loans also contained mandatory arbitration clauses that the MLA explicitly prohibits.⁴

A separate finding covered roughly 15,000 loans on which TitleMax had charged fees for an insurance product the CFPB described as providing no actual coverage, which also resulted in understated finance charges and APRs in violation of the Truth in Lending Act.³

The order required TitleMax to pay $5.05 million in consumer redress and a $10 million civil penalty.⁴ All 2,670 loans to covered military borrowers were declared void from inception, meaning affected servicemembers and dependents owed nothing further on them.⁵ Redress also covered interest paid on the illegal insurance fees and losses tied to vehicles that had been wrongfully repossessed or sold.³ TMX Finance denied the factual and legal allegations, stating it agreed to the fine to avoid costly litigation.⁶

The Blackmon Military Lending Class Action

The CFPB order did not close off private claims. On February 21, 2024, a proposed class action titled Blackmon v. TitleMax of Georgia, Inc. was filed in the U.S. District Court for the Northern District of Georgia, alleging a “systematic nationwide scheme” to issue illegal high-interest title loans to active-duty servicemembers and their dependents. The plaintiff, a Georgia resident and military spouse, said she was told TitleMax would “make an exception” to its policy against lending to military families when she received a $2,518 loan in September 2021 and a $1,318 loan in July 2022.⁷

The suit seeks at least $500 per MLA violation for each class member.⁷ TitleMax answered in January 2025, denying the substantive allegations and arguing that the plaintiff’s claims are moot because the CFPB consent order already provided the relief sought.⁸ The case is at the pleading stage with no ruling yet on class certification.

The 4.8 Million-Person Data Breach Settlement

In early December 2022, hackers gained access to TMX Finance’s systems. The company did not discover the breach until February 13, 2023.⁹ The exposed data included names, dates of birth, Social Security numbers, driver’s license and passport numbers, tax identification numbers, financial account information, phone numbers, and email addresses for about 4.8 million individuals.¹⁰

The consolidated class action, Kolstedt v. TMX Finance Corporate Services, Inc., was filed March 31, 2023 in the U.S. District Court for the Southern District of Georgia before Judge R. Stan Baker.¹¹ Plaintiffs alleged inadequate security enabled the breach and brought claims under state consumer protection statutes.¹⁰

What Class Members Could Recover

The settlement website described a $6.5 million fund with three components: up to $4.5 million for undocumented losses paid as a flat $35 per claimant; up to $2 million for documented out-of-pocket losses capped at $500 per person; and a one-time $20 credit applied to outstanding loan balances for class members who did not file a claim.¹² Attorneys’ fees of up to $5.75 million were funded separately by the defendants.¹³ Judge Baker granted final approval, which Bloomberg Law reported as a $12 million deal reflecting the total value including separately funded fees and additional relief.¹⁰ Payments to approved claimants began December 3, 2025.

The $52.7 Million Pennsylvania Enforcement Action

The largest pending exposure is a Pennsylvania administrative case. On June 14, 2024, the Pennsylvania Department of Banking and Securities issued an Order to Show Cause accusing TitleMax and seven affiliates of entering into at least 5,270 loan agreements with Pennsylvania residents between July 2008 and September 2017 without ever obtaining a license under the state’s Consumer Discount Company Act. Interest rates on those loans reached as high as 720 percent, far above the state’s 6 percent cap for unlicensed lenders under the Loan Interest and Protection Law. The Department is seeking $10,000 per violation, totaling $52.7 million, plus restitution to affected borrowers.¹⁴

TitleMax tried to route around the state proceeding. TMX Finance Corporate Services sued in the Northern District of Texas in August 2024, arguing it was a separate entity and that the Pennsylvania order was unconstitutional. The case was dismissed, and on January 9, 2026, the Fifth Circuit unanimously affirmed, finding TitleMax had adequate opportunity to raise its constitutional arguments in Pennsylvania’s own tribunal.¹⁵ On April 21, 2026, the Pennsylvania Commonwealth Court dismissed TitleMax’s parallel state appeals as premature.¹⁶ TitleMax must now defend the case on the merits, and the $52.7 million question remains open.

How TitleMax’s Arbitration Clauses Have Fared

TitleMax loan agreements typically include mandatory arbitration clauses, and those clauses have produced mixed results. In November 2023, the Missouri Court of Appeals ruled against TitleMax in Brown v. TitleMax of Missouri, Inc., one of ten consolidated proceedings. The American Arbitration Association had declined to administer claims against TitleMax because the company failed to comply with AAA registration policies, and the court held that the plaintiffs could take their claims to court instead.¹⁷

In Goins v. TitleMax of Virginia, an arbitrator found that TitleMax’s title loans violated North Carolina’s Consumer Finance Act and usury statutes, ordering treble damages exceeding $365,000. The U.S. District Court for the Middle District of North Carolina denied TitleMax’s motion to vacate the award in January 2023, observing that by insisting on arbitration, TitleMax had given up the appellate review a court proceeding would have offered.¹⁸

Where TitleMax Still Operates

Title lending law varies sharply by state, and TitleMax has withdrawn from several. At least five states have capped interest rates at 36 percent annually, and TitleMax exited Illinois, Virginia, and California after those caps took effect.¹⁹⁶²⁰ Whether you have a claim, and what kind, depends heavily on which state’s loan you took out and when.

1
Consumer Financial Protection Bureau. TMX Finance LLC Enforcement Action (2016)
2
Center for Responsible Lending. TitleMax Deserves Fine for Abusive Practices
3
Consumer Financial Protection Bureau. CFPB Orders TitleMax to Pay a $10 Million Penalty for Unlawful Title Loans and Overcharging Military Families
4
Consumer Financial Protection Bureau. TMX Finance LLC Enforcement Action (2023)
5
Consumer Financial Protection Bureau. TMX Finance LLC Consent Order (2023)
6
TMX Finance Family of Companies. TitleMax Statement on CFPB Consent Order
7
ClassAction.org. TitleMax Facing Military Lending Act Lawsuit Over Alleged High-Interest Title Loans
8
Consumer Advocates. Blackmon v. TitleMax Answer to First Amended Complaint
9
Edelson Lechtzin LLP. TMX Finance Corporate Services Data Breach Investigation
10
Bloomberg Law. TitleMax’s $12 Million Data Breach Deal Gets Final Court Nod
11
CourtListener. Kolstedt v. TMX Finance Corporate Services Inc.
12
TMX Data Security Settlement. TMX Data Security Settlement
13
ClaimDepot. TMX Data Security Settlement
14
Pennsylvania Department of Banking and Securities. TitleMax Order to Show Cause
15
ABA Banking Journal. Fifth Circuit Affirms Dismissal of TMX Finance Corp’s Lawsuit Challenging Pennsylvania Interest Rate Cap Enforcement
16
Pennsylvania Commonwealth Court. TitleMax Commonwealth Court Opinion
17
FindLaw. Brown v. TitleMax of Missouri Inc.
18
Ellis & Winters LLP. Arbitrating Section 75-1.1 Claims: Blessing or Curse
19
ProPublica. Title Lenders Trap Georgia Residents in Debt
20
The Current GA. TitleMax Ordered to Pay $15 Million for Predatory Lending to Soldiers’ Families