CFPB receives unprecedented degree of reviews on payday, title and installment loan proposal that is high-cost

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

We’ve submitted feedback with respect to a few consumers, including commentary arguing that: (1) the 36% all-in APR “rate trigger” for defining covered longer-term loans functions as an unlawful usury limitation; (2) numerous provisions of this proposed guideline are unduly restrictive; and (3) the coverage exemption for many purchase-money loans payday loans MO is expanded to pay for short term loans and loans funding product product sales of solutions. Along with our feedback and people of other industry people opposing the proposition, borrowers at risk of losing use of covered loans submitted over 1,000,000 mostly individualized responses opposing the limitations regarding the proposed guideline and people in opposition to covered loans submitted 400,000 reviews. As far as we all know, this known degree of commentary is unprecedented.

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