3. Other Advantages and Expenses

3. Other Advantages and Expenses

Other advantages and expenses that the Bureau would not quantify are discussed within the Reconsideration NPRM’s part 1022(b)(2) analysis to some extent VIII.E. Included in these are ( but they are not restricted to): the customer welfare effects connected with increased usage of car name loans; intrinsic energy (“warm glow”) from usage of loans which are not utilized ( and therefore wouldn’t be available beneath the 2017 last Rule); revolutionary regulatory approaches by States that could have now been discouraged because of the 2017 Final Rule; general public and private wellness costs that could (or may well not) result from payday loan use; modifications towards the profitability and industry framework that will have took place reaction to the 2017 last Rule ( e.g., industry consolidation that will produce scale efficiencies, motion to installment item offerings); issues about Start Printed web web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or costs to outside events linked to the change in access to pay day loans; indirect expenses as a result of increased repossessions of cars in reaction to non-payment of car name loans; non-pecuniary expenses associated with monetary anxiety which may be eased or exacerbated by increased access to/use of pay day loans; and any effects of fraud perpetrated on loan providers and opacity as to borrower behavior and history associated with a not enough industry-wide subscribed information systems ( ag e.g., borrowers circumventing loan provider policies against using multiple concurrent pay day loans, loan providers having more trouble distinguishing chronic defaulters, etc.). (more…)