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Payday Alternative Loan Advanced Notice of Proposed Rulemaking

Payday Alternative Loan Advanced Notice of Proposed Rulemaking

Included in the 2020 guideline making procedure, the Board suggested that it would review PALs

We loan information gathered on FCU call reports after one year to reevaluate certain requirements of this PALs I rule. 17 As of September 2011, 372 FCUs offered PALs I loans with an aggregate stability of $13.6 million or 36,768 outstanding loans. 6 months later on, at the time of March 31, 2012, around 386 FCUs reported offering PALs we loans by having a balance that is aggregate of13.5 million on 38,749 outstanding loans. Although the Board acknowledged during those times that some FCUs might create a separate business choice to not ever provide PALs we loans, it nevertheless sought to boost how many FCUs making PALs we loans in a significant method and also to make certain that all FCUs that decided on to provide PALs we loans could actually recover the expenses related to making these kind of loans.

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The Board issued an advanced notice of proposed rulemaking (PALs I ANPR) seeking comments on specific aspects of the PALs I rule at its September 2012 meeting for that reason. 18 These concerns included, but weren’t limited by, asking perhaps the Board should allow an FCU to charge a greater application cost, perhaps the Board should raise the permissible PALs I loan rate of interest, and perhaps the Board should expand the most loan amount that is permissible.