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CFPB gets unprecedented degree of opinions on payday, title and high-cost installment loan proposition

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CFPB gets unprecedented degree of opinions on payday, title and high-cost installment loan proposition

Customer Finance Monitor

CFPB, Federal Agencies, State Agencies, and Attorneys General

The remark duration for the CFPB’s proposed guideline on Payday, Title and High-Cost Installment Loans ended Friday, October 7, 2016. The CFPB has its own work cut fully out it has received for it in analyzing and responding to the comments.

We’ve submitted remarks with respect to a few consumers, including reviews arguing that: (1) the 36% all-in APR “rate trigger” for defining covered longer-term loans functions being an usury that is unlawful; (2) numerous provisions associated with proposed guideline are unduly restrictive; and (3) the coverage exemption for many purchase-money loans must be expanded to pay for quick unsecured loans and loans funding product product sales of solutions. Read More