August 2020

3. Other Advantages and Expenses

Other advantages and expenses that the Bureau would not quantify are discussed into the Reconsideration NPRM’s part 1022(b)(2) analysis to some extent VIII.E. Included in these are ( but they are not restricted to): the customer welfare effects related to increased usage of automobile name loans; intrinsic energy (“warm glow”) from usage of loans that aren’t utilized ( and that wouldn’t be available underneath the 2017 last Rule); innovative regulatory approaches by installment loans north dakota States that will were discouraged by the 2017 Final Rule; general general public and private wellness expenses which will (or might not) result from payday loan use; modifications towards the profitability and industry framework that will have took place response to the 2017 last Rule ( ag e.g., industry consolidation which will produce scale efficiencies, motion to installment item offerings); issues about Start Printed web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or expenses to outside events from the improvement in access to pay day loans; indirect expenses as a result of increased repossessions of automobiles as a result to non-payment of car name loans; non-pecuniary expenses related to monetary anxiety that could be reduced or exacerbated by increased access to/use of payday advances; and any effects of fraud perpetrated on lenders and opacity as to borrower behavior and history pertaining to too little industry-wide authorized information systems ( e.g., borrowers circumventing loan provider policies against taking numerous concurrent payday advances, loan providers having more trouble pinpointing chronic defaulters, etc.).