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Vehicle title loans, however, are substantially larger than payday loans, with a median loan amount of nearly $700, twice that of payday loans.
Under § 1031(c) of the Dodd-Frank Act, the Bureau shall have no authority to declare an act or practice unfair unless it has a reasonable basis to conclude that it “causes or is likely to cause substantial injury to consumers which is not reasonably avoidable by consumers” and such substantial, not reasonably avoidable injury “is not outweighed by countervailing benefits to consumers or to competition.
The Bureau believes that these changes should be highlighted for consumers to understand the risks, attempt to plan for changed payments, and determine whether their authorization is being used appropriately.