CFPB gets unprecedented amount of reviews on payday, title and high-cost installment loan proposition

CFPB gets unprecedented amount of reviews on payday, title and high-cost installment loan proposition

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 fully out because of it in analyzing and responding into the reviews this has gotten.

We now have submitted reviews with respect to a few consumers, including remarks arguing that: (1) the 36% all-in APR “rate trigger” for defining covered longer-term loans functions being an unlawful usury limitation; (2) numerous provisions regarding the proposed guideline are unduly restrictive; and (3) the protection exemption for several purchase-money loans must certanly be expanded to pay for short term loans and loans funding product sales of solutions.

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