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The Bureau further seeks comment on whether a general “substantially smaller” standard is appropriate to prevent the unfair and abusive practice; whether a specific percentage reduction would be more appropriate; and, if so, what specific threshold or methodology should be used and why that number or formula appropriately differentiates substantially smaller payments, top online payday loans in Texas.
The Bureau does not have information about the frequency with which borrowers currently take out loans that would likely be originated as Portfolio approach loans, but given that these are all longer-term loans, the Bureau expects that the impact of this limitation would be small.
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The Bureau believes that lenders could obtain much of this revenue without engaging in the practice of trying to withdraw payment from consumers' accounts after the accounts have exhibited clear signs of being in severe distress.
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