By Z. Kaelin. Pfeiffer University.

For all of these reasons instant online payday loan approval, the Bureau believes that it is appropriate for the electronic short notice to contain less information than the full payment notice given that it links to the full notice bad credit payday loan online. As discussed further below emergency payday loan, the Bureau believes that providing access to the full notice via the website link would appropriately balance related concerns to ensure that consumers could access the full set of notice information in a more secure, usable, and retainable manner. The Bureau seeks comment on this proposed electronic short notice, including whether additional information should be excluded from the truncated notice. The Bureau seeks comment in particular on whether the readability and privacy concerns for email are outweighed by concerns 824 that requiring consumers to click through to the website to access the full notice information will make it less likely that consumers receive the full benefit of the information. Proposed comment 15(c)(2)-1 explains that when a lender provides the electronic short notice by email, the identifying statement must be provided in both the subject line and the body of the email. The Bureau believes that the date and the amount of the transfer are the most important pieces of information for the consumer to understand the costs and risks of the forthcoming payment transfer and take appropriate action. Additionally, participants in the Bureau’s 825 consumer testing expressed comfort with the legitimacy of the notice due to its inclusion of the consumer’s account information. Accordingly, the Bureau believes that this should be required as well in the electronic short notice. Consumers would be able to obtain all of the information contained in the full disclosure by accessing the link contained in the electronic short notice. The Bureau seeks comment on the information included in the electronic short notice. The Bureau believes that consumers should have access to the full notice content, but also understands the format restrictions of mobile devices and text message may limit the utility of providing all of this information through electronic delivery. Through this proposed two-step electronic delivery process, the Bureau is attempting to balance information access with these format considerations. However, the Bureau realizes that this proposed solution may not perfectly accommodate all consumers. The Bureau is aware that some consumers may not have internet capability on their phones and may not be able to open up the website when they receive a text message. For those consumers with no means of internet access (and who nonetheless consent to receive electronic disclosures), the Bureau believes that the truncated payment notice information, which takes into account the formatting and character limits of text messages, still provides useful information. If the information in the electronic short notice is inconsistent with the consumer’s expectations, the consumer could reach out to the lender for additional information or assistance. The Bureau seeks comment on the burden on lenders of hosting, posting, and taking down notices on a webpage. It also seeks comment on alternative methods of electronic delivery that may be less burdensome. The Bureau invites comment on the proposed two-step disclosure process for electronic delivery, including whether the website link to the full payment notice introduces significant privacy concerns and whether more secure options for electronic delivery are available. The Bureau is aware that there may be additional methods of providing the disclosures required by § 1041. The Bureau believes that the explanation of how the transfer may differ from the consumers’ expectation is important information that needs to be included in the electronic short 827 notice in order for the notice to be effective, pursuant to section 1032 of the Dodd-Frank Act. As discussed above, when a payment differs from the consumer’s expectations, the payment may pose greater risk of triggering overdraft or non-sufficient funds fees. The Bureau believes that consumers should be informed when a lender has triggered proposed § 1041. The Bureau is also concerned that some lenders would pressure consumers to provide affirmative consent and could 828 present the reasons behind the re-initiation limit in an incomplete manner. Requiring disclosure of prior failed payments and consumer rights under proposed § 1041. Due to these policy considerations, the Bureau believes that a lender should be required to provide a standardized consumer rights notice after it has initiated two consecutive failed withdrawals. The Bureau seeks comment on the proposed content and timing requirements of the consumer rights notice. Proposed comment 15(d)(2) clarifies that this timing requirement is triggered whenever the lender or its agent, such as a payment processor, receives information that the payment transfer has failed. When a lender has initiated two consecutive failed payment transfers and triggers the protections provided by proposed § 1041. In the meantime, some loans may accrue interest or fees while the balance remains unpaid. For these reasons, the Bureau believes that the consumer rights notice should be provided shortly after the second attempt fails. However, the Bureau is aware that, depending on the payment method, there may be a delay between the lender’s initiation of the payment transfer and information that the payment transfer has failed. Accordingly, the Bureau is proposing that the lender be required to 829 send the consumer rights notice within three business days after the lender receives information that the payment transfer has failed. The Bureau seeks comment on this timing requirement, including whether it is appropriate in length and whether it accommodates all payment channels. The Bureau invites comment on whether this timing requirement should be included, or whether the requirement for lenders to provide the consumer rights notice before obtaining a consumer’s reauthorization under proposed § 1041. The Bureau believes that a consumer should know that a lender has triggered the provisions in proposed § 1041. The Bureau believes that it may be important to inform consumers that Federal law prohibits the lender from initiating payments.

The Bureau anticipates that in some cases cash payday loan quick, the national consumer report the lender obtains will not include a particular debt obligation stated by the consumer oregon payday loan, or that the national consumer report may include payday car loan, for example, the payment amount under the debt obligation but not the timing of the payment. Similar anomalies could occur with covered loans and a consumer report obtained from a registered information system. To the extent the national consumer report and consumer report from a registered information system omit information for a payment under a debt obligation stated by the consumer, the lender would simply base its projections on the amount and timing stated by the consumer. For the reasons previously discussed, the Bureau believes that verification evidence is critical to ensuring that consumers in fact have the ability to repay a loan, and that therefore the costs are justified to achieve the objectives of the proposal. The Bureau invites comment on whether to require lenders to obtain credit reports from a national credit reporting agency and from a registered information system. In particular, and in accordance with the recommendation of the Small Business Review Panel, the Bureau invites comments on ways of reducing the operational burden for small businesses of verifying consumers’ payments under major financial obligations. The Bureau anticipates that some required payments under court- or government agency-ordered child support obligations will not appear in a national consumer report. To the extent the national consumer report omits information for a required payment, the lender could simply base its projections on the amount and timing stated by the consumer, if any. Proposed comment 5(c)(3)(ii)(D)-1 explains that the proposed provision means a lender would have three methods that it could choose from for complying with the requirement to obtain verification evidence for a consumer’s housing expense. A lender would be required to obtain a national consumer report as verification evidence of a consumer’s payments under debt obligations generally, pursuant to proposed § 1041. A lender’s compliance with that requirement would satisfy the requirement in proposed § 1041. It clarifies that for purposes of this method, reliable transaction records include a facially genuine original, photocopy or image of a receipt, cancelled check, or money order, or an electronic or paper record of depository account transactions or prepaid account transactions 334 (including transactions on a general purpose reloadable prepaid card account, a payroll card account, or a government benefits card account), from which the lender can reasonably determine that a payment was for housing expense as well as the date and amount paid by the consumer. This method mirrors options a lender would have for obtaining verification evidence for net income. Accordingly, data derived from a record of depository account transactions or of prepaid account transactions, such as data from account data aggregator services that obtain and categorize consumer deposit account and other account transaction data, would also generally satisfy the requirement. Bureau staff have met with service providers that state that they currently provide services to lenders and are typically able to identify, for example, how much a particular consumer expends on housing expense as well as other categories of expenses. It provides that, alternatively, a lender may estimate individual or household housing expense based on housing expense and other data (e. It further explains that a lender may estimate a consumer’s share of 335 household expense based on estimated household housing expense by reasonably apportioning the estimated household housing expense by the number of persons sharing housing expense as stated by the consumer, or by another reasonable method. Several lender representatives expressed similar concerns during the Bureau’s outreach to industry. The Small Business Review Panel Outline referred to lender verification of a consumer’s rent or mortgage payment using, for example, receipts, cancelled checks, a copy of a lease, and bank account records. Few consumers receive receipts or cancelled checks for rent or mortgage payments, they stated, and bank account statements may simply state the check number used to make a payment, providing no way of confirming the purpose or nature of the payment. Consumers with a lease would not typically have a copy of the lease with them when applying for a covered loan, they stated, and subsequently locating and transmitting or delivering a copy of the lease to a lender would be unduly burdensome, if not impracticable, for both consumers and lenders. The Bureau believes that many consumers would have paper or electronic records that they could provide to a lender to establish their housing expense. In addition, as discussed above, information presented to the Bureau during outreach suggests that data aggregator services may be able to electronically and securely obtain and categorize, with a consumer’s consent, the consumer’s deposit account or other account transaction data to reliably identify housing expenses payments and other categories of expenses. The Bureau’s proposal also is intended to facilitate automation of the methods of obtaining the verification evidence, making projections of a consumer’s housing expense, and calculating the amounts for an ability-to-repay determination, such as residual income. Similarly, a consumer may make payments in cash to another person, who then makes the payment to a landlord or mortgage servicer covering the housing expenses of several residents. During outreach with industry, one lender stated that many of its consumers would find requests for documentation of housing expense to be especially intrusive or offensive, especially consumers with informal arrangements to pay rent for a room in someone else’s home. To address these concerns, the Bureau is proposing the option of estimating a consumer’s housing expense based on the individual or apportioned household housing expenses of similarly situated consumers with households in the locality. The Bureau notes that if the method the lender uses to obtain verification evidence of housing expense for a consumer—including the 337 estimated method—indicates a higher housing expense amount than the amount in the consumer’s statement under proposed § 1041. Accordingly, a lender may prefer use one of the other two methods for obtaining verification evidence, especially if doing so would result in verification evidence indicating a housing expense equal to that in the consumer’s written statement of housing expense. The Bureau recognizes that in some cases the consumer’s actual housing expense may be lower than the estimation methodology would suggest but may not be verifiable through documentation. For example, some consumers may live for a period of time rent-free with a friend or relative. However, the Bureau does not believe it is possible to accommodate such situations without permitting lenders to rely solely on the consumer’s statement of housing expenses, and for the reasons previously discussed the Bureau believes that doing so would jeopardize the objectives of the proposal. The Bureau notes that the approach it is proposing is consistent with the recommendation of the Small Dollar Roundtable which recommended that the Bureau permit rent to be verified through a “geographic market-specific …valid, reliable proxy.

Age The age spread for high-cost short term loan consumers has remained remarkably consistent over the 2002-2008 period although there has been a slight increase in the proportion of older high-cost short term loan consumers payday loan payday uk. The 2002 study found the 26 to 35 year-old age category was the most common age category for high-cost short term loan consumers payday loan online fast, accounting for 9 38% of the survey sample payday loan in georgia. In both surveys, the mid-thirties to mid-forties year-old age bracket was the 10 next most heavily represented group (25% in 2002, and 24% in 2008). Following that, the eighteen to mid-twenties age group were the next most common representing 20% of the survey total in both 2002 and 2008. Again, the surveys produced similar results for the late forties to early fifties category. In 2002 it was found that 14% of high-cost short term loan 11 consumers were between 46 and 55 years old. As mentioned, the surveys did display some minor variance when it came to older age categories. In 2002, Wilson found only 3% of high-cost short term loan consumers were 12 over 56 years of age. In 2008 it was found that 7% of high-cost short term consumers were in the 54 to 64 year-old age category. The 2008 survey also found 1% of high-cost short term loan consumers were 65 years old or older. The next most common relationship status was partnered (those married or living in a de facto relationship), representing 26% 15 of high-cost short term loan consumers. Nineteen percent of high-cost short 13 In 2002, 17% of consumers were 46 years old or older. When broken down by gender it was found that 65% of male high-cost short term consumers were single, considerably higher than the 42% figure for women. For partnered respondents, there was no significant proportional 16 difference between men and women. The largest gender difference lay amongst those consumers who were separated or divorced. The 2002 study found 31% of female respondents fell into this category, which accounted for only 6% of men. This suggests that female sole parents are a 17 significant minority of payday loan consumers. Instead, the 2008 survey simply distinguished between being in a „couple‟ and „single‟ and then differentiated between those with children and those without. The 2008 survey also added the category „shared household with two or more adults‟, a category not included in the 2002 survey. The 2008 results show coupled consumers have increased their usage of high-cost short term lending and now account for 47% of the customer base. Conversely, singles now represent a much smaller proportion of high-cost short term loan consumers having dropped to 34% from the 55% majority registered in 2002. It is unclear whether some of this increase in the number of coupled consumers is due to some separated and divorced consumers categorising themselves as coupled rather than single, even if this did occur it would not account for all of the change. This might account for some of the drop in consumers who categorised themselves as single. On the 2008 results, female high-cost short term loan consumers are now just as likely to be single as men, with 34% of each gender registering as either single or single with children. Some of this change may be due to some separated and divorced females now categorising themselves as single. As was the case in 2002, it was found that female respondents were more likely to have dependent children. In 2002, it was found that 63% of female respondents had dependent children, 18 far more than the 23% of male respondents. Significantly, of the 44 survey respondents who clearly registered as sole parents in 2008 ("single with children"), 39 of them were women. This means 88% of sole parent high-cost short term loan consumers are female, which is only slightly lower than the 2002 figure of 92%. In 2002 it was found that 47% of all female high-cost short term loan consumers were sole parents, whereas this figure had dropped to 16% by 2008. However, the 2002 figure included both single and separated or divorced women, thus the change may be explained by the significant increase in high- cost short term loan consumers registering as in a couple. This confirms female sole parents remain an over represented minority amongst high-cost short term loan consumers - despite other changes that may have taken place. Although results were evenly spread, the most common age group for dependent children was 6 to 9 years (36%), with 10 to 14 being the next most common (32%). In 2002 part-time or casual employment accounted for only 12% of 20 respondents but had risen to 28. Full-time Part-time Not Full-time Centrelink or Casual Working student benefits 2002 49% 12% - - 38% 99% 2008 45% 28.

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