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Posted by on Dec 23, 2020 in | 0 comments

Pay day loan Rule Finalized: capability to Repay needs Narrowed, but Challenges and Risks Loom big

On October 5, 2017, the customer Financial Protection Bureau (the “CFPB”) released its last guideline focusing on just what it describes as “payday financial obligation traps” (the “Rule”). The Rule will require lenders to make “ability to repay” determinations before offering certain types of loans, including payday loans, auto title loans, and longer term loans with balloon payments among other things. Failure to try a proper underwriting analysis to evaluate a consumer’s ability to settle will represent an “abusive and unfair practice.” Industry individuals could

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