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Other Advantages and Expenses

Advantages or expenses to parties that are outside aided by the improvement in access to pay day loans

Other benefits and expenses that the Bureau would not quantify are discussed into the Reconsideration NPRM’s area 1022(b)(2) analysis to some extent VIII.E. These generally include ( but they are not limited to): the customer welfare effects related to increased usage of automobile name loans; intrinsic energy (???warm glow???) from use of loans that aren’t utilized ( and that wouldn’t be available under the 2017 last Rule); revolutionary regulatory approaches by States that will have already been frustrated because of the 2017 Final Rule; public and private wellness expenses which will or might not be a consequence of cash advance use; modifications into the profitability and industry framework that could have took place reaction to the 2017 last Rule ( e.g., industry consolidation which will create scale efficiencies, motion to installment product offerings); issues about regulatory doubt and/or inconsistent regulatory regimes across areas; indirect expenses as a result of increased repossessions of automobiles in reaction to non-payment of car name loans; non-pecuniary expenses related to economic anxiety that could be reduced or exacerbated by increased access to/use of payday advances; and any effects of fraud perpetrated on loan providers and opacity as to borrower behavior and history linked to a absence of industry-wide RISes (e.g., borrowers circumventing loan provider policies against using numerous concurrent payday advances, loan providers having more trouble pinpointing chronic defaulters, etc.). More…