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”