Somethings are just meant to be. The Mets are almost always going to be no better than a slightly above average baseball team, destined to leave their fans in stunned disbelief like a bride left at the altar; payday loans will always be around: The question is how best to regulate them?
The NCUA took a shot at answering this question when it submitted a letter commenting on the CFPB’s Payday Loan proposal. It not only argues that the CFPB should categorically exempt PAL loans from these regulations but it also advocates for a numerical threshold below which financial institutions could make loans that are technically payday loans without complying with the regulation, thereby letting them avoid the underwriting and disclosure requirements proposed by the CFPB. The Association makes an almost identical argument in its comment letter to be submitted to the Bureau. Here is why a threshold makes sense.continue reading »