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.