2018 Talking Points
This would remove the double counting of fees in the 3% Fee Cap. Currently, certain fees are calculated in the APR and additionally counted in the 3% Cap. This has several unintended consequences that harm the consumer, including under some circumstances, being able to buy down the interest rate.
Currently, the act of pulling a credit report on a transaction, triggers leads generated for other lenders, subjecting consumers to a barage of unexpected and unwelcome solicitations.
Currently, the CFPB is not required to give guidance to the industries they regulate. Their current method of communication is by massive rules followed by huge penalties and filing law suit. This bill would require CFPB to give guidance and answer industry questions.
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