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The department also plans to establish a new complaint system allowing borrowers to have their concerns addressed.
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Potential Benefits and Costs of the Proposed Rule to Consumers and Covered Persons—Provisions Relating Specifically to Covered Short-Term Loans
In particular, the Bureau solicits comment on other methods of supplementing the basic ability-to-repay determination required for a covered longer-term loan shortly following a covered short-term loan or covered longer-term balloon-payment loan.
However, the Bureau believes that such a disclosure remedy would be significantly less effective in preventing the harms described above, for three reasons.