Federal Deception Law: 3.2.4.4.2 Analysis from Payday Lending Rule’s Supplemental Information
The Federal Register notice accompanying the CFPB’s final payday lending rule explains how consumers fail to understand the material risks and costs of payday, auto title, and similar loans.153 While consumers certainly understand that they are taking out a loan that must be repaid by a certain date, and that there are consequences for non-payment, they do not understand how severe the impact of non-payment is or that non-payment is very likely for these loans.