Customer Financial Services Review

Customer Financial Services Review

On June 2, 2016, the CFPB proposed brand new ability-to-repay and re re re payment processing demands for short-term and particular longer-term customer loans. Relying mostly regarding the CFPB’s authority to prohibit unjust or abusive techniques, the proposition would generally need that lenders making payday, car name, and particular high-rate installment loans either originate loans satisfying strict product characteristic limitations set by the guideline or make an ability-to-repay determination predicated on verified earnings as well as other information.

The CFPB is also proposing to establish special “registered information systems” to which lenders would have to report information about these loans to facilitate the ability-to-repay determination. In addition, servicers would need to obtain brand new repayment authorizations from consumers after making two consecutive unsuccessful attempts at installment loans with bad credit south carolina extracting payment from customer records, and could be susceptible to new disclosure demands linked to re re payment processing. […]