Re Re Payment Restrictions

Re Re Payment Restrictions

All covered loans, whether short-term or longer-term, are at the mercy of particular collection limitations. The CFPB has cited to the “substantial risk of consumer harm, including substantial fees and, in some cases, the risk of account closure” which may come if lenders are allowed to collect payment from consumers’ checking, savings and prepaid accounts as rationale for the restriction. See Outline of Proposals into consideration and Alternatives Considered, p. 28 (Mar. 26, 2015).

The proposed rule contains two key notice needs.

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