In reality, the Bureau supports its presumptions in line with the belief that most covered loans result consumer harm
As a far more practical thing, nowhere within the 1,300 plus web page proposition do the Bureau try to quantify the advantages to people associated with the proposed provisions, rather depending on duplicated expressions along the lines of “it generally seems to the Bureau” or that the “Bureau believes” that “the level of injury that is due to the unjust procedures, when you look at the aggregate, seems to be extremely high.” The Proposal cites reports that are numerous research to justify these panorama, but doesn’t add any metrics in their research of importance and prices.
This theme try unsupported and straight disputes with amount of research from the problem, which casts question regarding the idea that utilize of covered loans adversely impacts borrowers.[9] We think this to feel a fundamental flaw in the thinking associated with Bureau as beneath the Dodd-Frank work a training can not be “unfair” if any injury it produces was outweighed by countervailing advantages. And usually, a practice that is“abusive just take “unreasonable” benefit of customers.