You might not like this either. Last week the Consumer Financial Protection Bureau (CFPB) entered their rulemaking process to establish approaches that will eliminate the “payday loan” debt traps marketed to financially vulnerable consumers. These rules may address lenders’ failure to underwrite for affordable payment, rolling over or refinancing loans, and other duplicitous practices.
We may see the new catch phrase of Debt Trap Prevention (DTP) instead of OCP as a challenge to politicians who give deference to their hard working lobbyists over their hard working constituents. http://ourfinancialsecurity.org/blogs/wp-content/ourfinancialsecurity.org/uploads/2014/12/Payday-pay-to-play-final.pdf.
But, speaking of failure to underwrite, merchant underwriters and monitors must take care to assure their processing accounts stay within the rules lest they be accused of complicity with the lenders. (Think Four Oaks Bank, CommerceWest Bank and Plaza Bank).
http://www.consumerfinance.gov/newsroom/cfpb-considers-proposal-to-end-payday-debt-traps/