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During the SBREFA process, Bureau considered, and included in the Small Business Review Panel Outline with regard to the maximum payment-to-income alternative, prohibiting lenders from making a loan under § 1041.
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No credit report is pulled because those with emergency cash needs have already exhausted their options.
An ability-to-repay determination that is based on unrealistic factual assumptions will yield unrealistic and unreliable results, leading to the consumer harms that the Bureau's proposal is intended to prevent.
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While other sources on vehicle title lending are more limited than for payday lending, the Tennessee Department of Financial Institutions publishes a biennial report on vehicle title lending.
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A MACC is a Medium Amount Credit Contract which is defined in the National Consumer Credit Protection Act (NCCP Act) as a loan, which may vary in length from 16 days to 2 years and can be from $2050 to $5000.