September 21, 2016 | Research & Surveys
Rich Hackett (Nonprime 101)
ONE-PAGER: Evaluating CFPB Simulations of the Impact of Proposed Rules on Storefront Payday Lending
FULL STUDY: Evaluating CFPB Simulations of the Impact of Proposed Rules on Storefront Payday Lending
This paper evaluates the CFPB’s simulation findings, using a different, larger dataset than that chosen by the CFPB, a dataset that also includes debt service and living expense obligations for storefront payday borrowers. This latter information allows us to provide a more complete simulation of the effect of the CFPB’s proposal – a simulation of the “ability-to-repay” (ATR) requirement that was not included in CFPB’s Supplemental Findings.