The effect of the fee thresholds on small-dollar lending must be evaluated in 270 days
What the document says“Not later than 270 days after the date of enactment of this Act, the Director of the Bureau of Consumer Financial Protection, in consultation with the Secretary of Housing and Urban Development and the Director of the Federal Housing Finance Agency, shall evaluate the impact of the thresholds under section 1026.43 of title 12, Code of Federal Regulations (as in effect on the date of enactment of this Act), on small-dollar mortgage originations.”
The section requires the Director of the Bureau of Consumer Financial Protection, consulting the Secretary of Housing and Urban Development and the Director of the Federal Housing Finance Agency, to evaluate within 270 days of enactment how the thresholds in section 1026.43 of title 12 of the Code of Federal Regulations, as in effect on the date of enactment, affect the making of small-dollar mortgages.
What the document actually says“Not later than 270 days after the date of enactment of this Act, the Director of the Bureau of Consumer Financial Protection, in consultation with the Secretary of Housing and Urban Development and the Director of the Federal Housing Finance Agency, shall evaluate the impact of the thresholds under section 1026.43 of title 12, Code of Federal Regulations (as in effect on the date of enactment of this Act), on small-dollar mortgage originations.”
A consumer agency must weigh what one federal rule does. The rule sets limits tied to home loans. The question is how those limits affect small loans. Two other agencies must be asked along the way.
The rule named here is about the fees a home loan may carry. Small loans have small balances. A fee cap set as a share can bite harder on them.
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