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Does the proposition provide any alternatives for short term installment loans that don’t require an ATR analysis?

Does the proposition provide any alternatives for short term installment loans that don’t require an ATR analysis?

The Bureau acknowledges it does provide a short, non exclusive list of actions that might be taken with such an intent that it cannot anticipate every possible way in which lenders could evade the requirements of the proposed rule, but. These generally include different charge structures in addition to ways of changing the character of that loan after consummation.

What kinds of loans are “covered loans” underneath the proposed guideline?

The proposed guideline provides two kinds of covered loans. A “covered loan” means closed end or available end credit this is certainly extended to a consumer mainly for personal, family members, or home purposes that isn’t excluded by the guideline. Especially, covered loans are: short term installment loans of 45 times or less, including pay day loans, deposit advance items, car name loans, installment loans, and open end credit lines; and