CFPB gets unprecedented standard of remarks on payday, title and installment loan proposal that is high-cost
We’ve submitted feedback with respect to a few customers, 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) multiple provisions associated with the proposed guideline are unduly restrictive; and (3) the protection exemption for several purchase-money loans must certanly be expanded […]