What, if anything, should the Consumer Financial Protection Bureau do to regulate payday lending? Nathalie Martin has this post at Credit Slips in which she notes that although the CFPB cannot cap interest rates (which she suggests would be ill-advised anyway), the agency should consider a number of regulatory options, including:
1. A National database for all loans (and if ... [the loan is not in the database, the loan] is not enforceable).
2. A strict limit on rollovers and total loans per year per customers.
3. Disclosures that consumers can read and understand (not typical TILA garbage), given in the store, in huge print on the documents, and pointed out and repeated orally by the clerk.These should be written or vetted by someone who teaches school at the level of the average reader in America.
4. No enforcement of mandatory arbitration clauses.
5. No enforcement of mandatory class action waivers.
6. Rules against certain kinds of advertising.