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However, if the new covered longer-term loan would be repayable in monthly payments of $100, then the exception in § 1041.
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Given the very low cost of electronic storage, however, the Bureau does not believe that this would impose a meaningful new burden on lenders.
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Although some individual consumers may be able to avoid the injury, as noted above, a large amount of the substantial injury is not reasonably avoidable.
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There are a lot of posts that analyze this question in depth including a great post at SoFI Fixed vs Variable.Staggering effective dates in one of these ways may increase to some degree the utility of the consumer reports that lenders would be required to obtain at the point that the requirements become effective, but may add complexity to implementation of the rule and would involve other tradeoffs, payday loans online direct lender.
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