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Government Affairs 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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