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The context for the research, and of the CFPB’s rulemaking, may be the CFPB theory that too numerous payday borrowers are caught in a “debt trap” comprising a number of rollovers or fast re-borrowings (the CFPB calls these “sequences”) where the “fees eclipse the mortgage quantity.” A sequence of more than 6 loans would constitute “harm” under this standard at the median fee of $15/$100 per pay period.
In March Clarity published a unique analysis built to steer clear of the flaws when you look at the CPFB approach, on the basis of the exact same big dataset. The study that is new A Balanced View of Storefront Payday Borrowing Patterns, uses a statistically legitimate longitudinal random test of the same big dataset (20% associated with the storefront market). This short article summarizes the Clarity that is new report. (more…)