Last month I wrote about the Consumer Financial Protection Bureau’s proposed rule to regulate “Payday, Vehicle Title, and Certain High-Cost Installment Loans,” and its intrusion into traditional vehicle finance. I’ve spent more time reviewing the proposed rule, and have concluded that the CFPB has very likely drafted a proposal that sets an effective usury cap in direct violation of the Dodd Frank Act’s (DFA) express prohibition on such action:
“No provision of this title shall be construed as conferring authority on the bureau to establish a usury limit applicable to an extensio
