At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter it submitted on the CFPB’s proposed payday/auto title/high-rate installment loan rule.
The CFPB’s proposal provides a method to calculate the total cost of credit used to determine whether a loan would be a “covered loan.” … Continue Reading