The Right to Deregulate: The CFPB’s Authority to Remove the Ability-to-Pay Requirement as it Pertains to Payday Lenders
Davisson, Ben
Abstract
The Consumer Financial Protection Bureau is proposing to rescind the rule requiring payday lenders to assess a borrower's ability to repay the loan. This article by Ben Davisson explores the Bureau's authority to rescind its own rule despite the potentially harmful effects on vulnerable low-income consumers.