A 25% cap seems like authorized robbery to me. And, probably robbery of those who can least understand what the rate/charges are (elderly, poor, minimumally educated).
Well, if the banks want to charge people the maximum amount (25%) perhaps:
1- they should be required to clearly tell customers the total of the rate and fees at least 60 days PRIOR to creating a new charge.
2- provide clear EXAMPLES of what is going to happen-(personally, I think the gov't [you] should create/author these examples and all financial institutions should have to include them. That way it can be a one page , easy to understand, LOOK OUT FOR THIS CRAP, and call us if there is a problem, here is our number... message)
3- tell the customer what options are available to them , including finding another financial institution
4- Financial institutions should have to report the demographics of who they are charging these fees. If they are targeting certain groups, I hope you have the power to shut them down.
Comment on CFPB-2012-0015
This is comment on Proposed Rule
Truth in Lending (Regulation Z)
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