A majority of commenters asked that the Board combine the PALs I rule and proposed PALs II rule together in a single PALs regulation in the PALs II NPRM. The majority of the commenters argued highly that one PALs loan legislation would reduce confusion and provide FCUs with greater freedom to format their PAL programs in ways that most readily useful serve their people.
A tiny quantity of commenters raised severe concerns concerning the applicability associated with CFPB’s payday lending rule 36 should the Board follow any changes into the PALs I rule. The CFPB’s payday financing rule establishes customer defenses for many credit that is high-cost, including pay day loans, and deems some credit methods associated with those services and products become unjust or abusive in breach regarding the customer Financial techniques Act. 37 nonetheless, the CFPB’s payday lending rule supplies a вЂњsafe harborвЂќ for any loan that is produced by an FCU in compliance aided by the PALs I rule with an explicit cross-reference to В§ 701.21(c)(7)(iii). 38 These commenters argued that any modifications into the PALs I rule may get rid of the harbor that is safe FCUs into the CFPB’s guideline.