3. Other Advantages and Expenses


3. Other Advantages and Expenses

Other advantages and expenses that the Bureau would not quantify are discussed into the Reconsideration NPRM’s part 1022(b)(2) analysis to some extent VIII.E. Included in these are ( but are not restricted to): the customer welfare effects related to increased usage of automobile title loans; intrinsic energy (“warm glow”) from use of loans that aren’t utilized ( and therefore wouldn’t be available underneath the 2017 Final Rule); revolutionary regulatory approaches by States that will have already been frustrated because of the 2017 last Rule; general public and private health expenses which will (or may well not) result from payday loan use; modifications towards the profitability and industry structure that will have happened in reaction to the 2017 last Rule ( e.g., industry consolidation which will produce scale efficiencies, motion to installment item offerings); issues about Start Printed web web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or expenses to outside events linked to the improvement in access to payday advances; indirect expenses due to increased repossessions of cars in reaction to non-payment of car title loans; non-pecuniary expenses associated with economic anxiety which may be reduced or exacerbated by increased access to/use of payday advances; and any effects of fraud perpetrated on loan providers and opacity as to borrower behavior and history pertaining to too little industry-wide authorized information systems ( ag e.g., borrowers circumventing loan provider policies against using numerous concurrent payday advances, loan providers having more trouble pinpointing chronic defaulters, etc.). 続きを読む “3. Other Advantages and Expenses”