Long-term Loan Portion of the Payday and Car Title Rulemaking
This letter urges the Bureau to establish a strong rule addressing payday, car title, and similar loans. It focuses on the migration of payday and car title lenders to long-term loans that keep borrowers trapped in prolonged unaffordable debt. This migration is already well underway in the states where long-term, high-rate loans are permitted, and lenders are already aggressively seeking authorization of these loans in states where it is not. A rule that does not prevent unaffordable lending in the long-term space will only fuel the migration and will permit ongoing, and in some cases even...