Effects associated with Proposed Payday Rule
The proposed rule absolves the consumer of any responsibility for good decision-making and is likely to have two key impacts: (a) make short-term credit harder for consumers to come by, and (b) contract the small lending market while there is no doubt there may be need for reform. These two effects are recognized by the CFPB consequently they are of concern to stakeholders.
The rule significantly curtails short-term loans, a fact acknowledged by the CFPB in its present form.
Effect on customers. The CFPB simulations suggest that making use of the power to repay choice (“prevention”), loan amount will probably fall between 69-84%. Their simulation, with the alternative option (“protection”), would end up in a 55-62% decrease in loan amount. Outline of Proposals into consideration and Alternatives Considered, pp. 40-44 (Mar. 26, 2015). These simulations account for just the more restrictive demands to be eligible for a short-term loans nor look at the impact that is operational loan providers (that will be discussed below). The CFPB concedes that because of this, it’s likely that “relatively few loans might be made underneath the ability-to-repay requirement.” Id., p. 45. Continua a leggere