The CFPB is considering whether to require the lender to assume that a consumer fully utilizes the credit upon origination and makes only minimum required payments until maturity, at which point the borrower pays off the credit in full for open-end lines of credit that terminate within 45 days or where the credit is repayable in full within 45 days. The lending company may also have to assume complete payment associated with loan by the re payment date.
The Proposal provides alternative much less onerous requirements for covered short-term loans that meet certain testing criteria and include specific structural defenses. Car name loans aren’t qualified to receive the approach that is alternative. The assessment requirements, besides the demands above that affect all short-term covered loans, include the immediate following: