AFSA Comments to CFPB on Payday Loan Disclosures
This week, the American Financial Services Association (AFSA) commented on the payday loan disclosures designed by the Consumer Financial Protection Bureau (CFPB).
AFSA emphasized that the definition of “payday loan” should be included in all the documents, especially in the “Initial Screener” questionnaire and the “Introduction of the Interview” transcript, to avoid the possible inclusion of non-payday lending data. AFSA suggested the inclusion of the following definition of a payday loan:
“A payday loan is a transaction for a fee involving accepting a check dated on the day it is written and held for a period of time before it is deposited. Payday loans do not include loans that are paid back in equal monthly payments over a set period of time.”
December 16th, 2020
