the customer Financial Protection Bureau (“CFPB” or “Bureau”) proposed a rule that is new its authority to supervise and manage specific payday, automobile title, as well as other high-cost installment loans (the “Proposed Rule” or the “Rule”). These customer loan items have been around in the CFPB’s crosshairs for quite a while, and also the Bureau formally announced it was considering a guideline proposition to finish just what it considers payday financial obligation traps straight back in March 2015. Over per year later on, along with input from stakeholders along with other interested events, the CFPB has taken direct aim at these financial products by proposing strict requirements that could make short-term and longer-term, high-cost installment loans unworkable for customers and lenders alike. At least, the CFPB’s proposal really threatens the continued viability of an important sector for the lending industry.
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