Product refunds and rate caps – what you need to know

Loan growth, resource deficiencies, and increasing regulations are some of the pain points financial institutions are currently feeling. Additionally, state by state regulations on rate caps are causing lending confusion, subprime originations are down, and the CFPB is enhancing operating laws for lender accountability on ancillary products, repossessions, and collections.

Some market conditions influencing these pain points include:
•  Increased unemployment leading to consumers struggling to make payments
•  New regulatory scrutiny stemming from a new presidential administration
•  Lack of consumer education around payment deferment versus forgiveness
•  An expected surge of repossessions as moratoriums end

These changes are a catalyst for lenders to look for additional protections, expand access to repossession and collection services, and increase understanding of state and federal guidelines.


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