Compliance Alliance Q&A 5-15-17

Question:

Are overdraft services excluded from the new Proposed Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans? What other types of credit are excluded?

Answer:

Overdraft services, including overdraft lines of credit, are explicitly excluded from the new Proposed Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans. Other types of credit that are also explicitly excluded are:

  • Purchase money security interest loans;
  • Real estate secured credit that is perfected;
  • Credit cards;
  • Student loans; and
  • Non-recourse pawn loans.

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