Compliance Alliance Q&A 5-15-17
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?
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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