CBA Comment Letter on CFPB’s Proposed Small-Dollar Rule

CBA Comment Letter on CFPB’s Proposed Small-Dollar Rule

Ms. Monica Jackson

Workplace for the Executive Secretary

Customer Financial Protection Bureau

1700 G Street, NW

Washington, DC 20552

Re: Docket No. CFPB-2016-0025 / RIN3170–AA40 – Payday, car Title, and Certain High-Cost Installment Loans

Dear Ms. Jackson,

The Consumer Bankers Association (“CBA”)1 appreciates the chance to offer our remarks in reaction to your customer Financial Protection Bureau’s (“Bureau” or “CFPB”) notice of proposed rulemaking for payday, automobile name, and specific high-cost installment loans (“Proposal”). CBA highly supports effective customer defenses and, especially, the concepts of preference, transparency and fairness in consumer relationships.

CBA commends the Bureau for examining the small-dollar credit marketplace and exactly how loan providers in the forex market meet consumers’ need for credit. We think its essential that customers get the services and products they desire and require at reasonable rates as well as on clear terms. We believe that it is incredibly important to weed away bad actors that engage in fraudulent deals or violate laws that are federal. Nevertheless, we think the Bureau’s Proposal will discourage depository that is traditional from staying in or going into the market.

The Bureau has proposed strict and prescriptive guidelines that may stifle progress into the market that is small-dollar.

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Payday advances Concerns and Responses. Do you really be eligible for a quick payday loan refund?

Payday advances Concerns and Responses. Do you really be eligible for a quick payday loan refund?

Pay day loan complaints have soared 60% within the previous 12 months. The Financial Ombudsman Service is predicting 500,000 pay loan complaints to lenders this year day. You may be element of it.

Then you are likely to get the money spent on interest and charges back if you answer YES to any of these questions:

Do you sign up for loans that are multiple different providers? (more…)

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