3. Other Advantages and Expenses

3. Other Advantages and Expenses

Other advantages and costs that the Bureau would not quantify are discussed when you look at the Reconsideration NPRM’s part 1022(b)(2) analysis in part VIII.E. Included in these are ( but are not limited to): the buyer welfare impacts related to increased access to car name loans; intrinsic energy (“warm glow”) from usage of loans which are not utilized ( and therefore wouldn’t be available underneath the 2017 last Rule); revolutionary regulatory approaches by States that could have already been frustrated by the 2017 last Rule; general public and private wellness expenses that could (or might not) result from payday loan use; modifications towards the profitability and industry framework that will have took place reaction to the 2017 last Rule ( e.g., industry consolidation which will produce scale efficiencies, motion to installment item offerings); concerns about Start Printed web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or costs to outside events from the improvement in access to pay day loans; indirect expenses due to increased repossessions of automobiles in reaction to non-payment of car title loans; non-pecuniary expenses connected with monetary anxiety that could be relieved or exacerbated by increased access to/use of pay day loans; and any effects of fraud perpetrated on loan providers and opacity as to borrower behavior and history associated with too little industry-wide authorized information systems ( ag e.g., borrowers circumventing loan provider policies against taking numerous concurrent payday advances, loan providers having more trouble pinpointing chronic defaulters, etc.). Continue reading “3. Other Advantages and Expenses”