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

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

Customer Finance Track

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 finished Friday, October 7, 2016. The CFPB has its work cut right out it has received for it in analyzing and responding to the comments.

We now have submitted commentary on the part of a few consumers, including commentary arguing that: (1) the 36% all-in APR “rate trigger” for defining covered longer-term loans functions as 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 ought to be expanded to pay for quick unsecured loans and loans funding product product product sales of solutions. […]

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