CFPB Problems Final Rule Regulating Pay Day Loans

Overview On October 5, 2017, the CFPB issued its last guideline on Payday, car Title, and Certain High-Cost Installment Loans, 12 C.F.R. pt. 1041. The rule requires lenders to determine that borrowers are able repay the loans and limits loan refinancing for certain short-term and balloon loans. The guideline additionally limits an ability that is lender’s repeatedly cash a check or debit a consumer’s account after two unsuccessful efforts. This debit limitation is applicable not just to all short-term and balloon loans, but to longer-term installment loans and personal lines of credit having an APR beneath the Truth in Lending Act that surpasses 36%.

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