CCUSA comments on Consumer Financial Protection Bureau proposed rule

October 3, 2016

CCUSA filed comments on the Consumer Financial Protection Bureau’s proposed rule on “Payday, Vehicle Title, and Certain High-Cost Installment Loans.”

CCUSA is deeply concerned that the proposed rule permits an exception from the borrower’s “ability to repay” standard and would allow for six 300% interest payday and car title loans in a year. Six unaffordable loans in one year is too many, as even a single unaffordable loan can create a cascade of financial consequences for borrowers.

CCUSA is also concerned with provisions that would allow for repeated flipping of loans which typically results in an ongoing cycle of debt.

Read the full letter.

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