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For the purposes of this proposal, the Bureau is focused on certain lender practices regarding refinancing where the circumstances suggest that the consumers are having difficulty repaying the outstanding loan.
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The proposed identification thus would apply to all common methods of withdrawing payment from consumers' accounts, including but not limited to the following methods: Electronic fund transfers (including preauthorized electronic fund transfers), without regard to the particular type of payment device or instrument used; signature checks; remotely created checks; remotely created payment orders; and an account-holding institution's withdrawal of funds held at the same institution.
The explanation for this is not simple, and a variety of economic jargon floats around the issue.
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Incorporating many of the conditions established by the NCUA for its Payday Alternative Loan program into a conditional exemption would create a narrow exemption to the general requirement of the Bureau's proposal to determine a consumer's ability to repay prior to making a covered longer-term loan.
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