Veritec Solutions Files Response to Proposed CFPB Rules on Payday, Vehicle Title, and Certain High-Cost Installment Loans

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Long-time provider of real-time regulatory solutions draws on years of experience & industry expertise to weigh in on the potential negative impacts of the CFPB's proposed rules on payday & other high-cost loan products.

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Veritec Solutions is the industry leader in real-time regulatory solutions.

Licensed small-dollar lending activity in states where Veritec manages real-time regulatory enforcement programs is 100% compliant with state laws protecting the consumer from unfair, deceptive, and abusive practices.

Veritec Solutions LLC, the industry leader in real-time regulatory solutions, submitted comments on October 6th in response to the Notice of Proposed Rulemaking on Payday, Vehicle Title, and Certain High-Cost Installment Loans released by the Consumer Financial Protection Bureau (CFPB or Bureau).

The proposed rule (Docket No. CFPB-2016-0025), released on June 1, 2016, solicited input from the public during a specified public comment period that extended through October 7, 2016. During this time, comments could be submitted to the Bureau through email, online entry, physical mail, or hand delivery. Veritec Solutions responded to the CFPB’s request for input, submitting 61 pages of comments online at http://www.regulations.gov on October 6, 2016.

For over 15 years, Veritec has managed regulatory database programs spanning 14 states. Our expertise in the industry stems from our extensive experience in the payday, vehicle title, and installment loan sector, as well as the strong relationships developed with regulators, lenders, and consumers. The response submitted by Veritec is based on factual data from numerous accredited sources cited in the full 61-page document, and includes the following comments:

Registered Information Systems (RIS):
The CFPB’s proposed multiple RIS report-to-all, check one approach should be streamlined to reduce high costs and burdens to lenders created by this “one-to-many” environment that requires lenders to enter redundant information into numerous different systems.

The Need for Real-Time Data Furnishing and Reporting:
Real-time data capture and reporting is required to enable lender compliance with consumer protections under the proposed rule. For audit purposes, regulators must know when qualifying information became available to a lender to ensure compliance for every transaction recorded. The application of a real-time policy enables lenders to adhere to regulations based on real-time nationwide information, allowing lenders to issue only the loans for which all requirements have been met.

States Currently Using Real-Time Enforcement:
Roughly half of states that regulate small-dollar lending use a Veritec-managed statewide regulatory database for real-time enforcement. Licensed small dollar lending activity in these states is 100% compliant with state laws which effectively address unfair, deceptive, and abusive acts or practices. Veritec challenges the CFPB’s findings which did not include research and analysis of entire datasets from several of these states which were made available to the CFPB. Analysis of data from these states contrasts effectiveness of consumer protections in these environments compared to states with no real-time enforcement.

Data Standards:
Veritec expressed the importance of common RIS standards and concern about the Bureau’s proposed process to foster development of standards across the RIS environment.

Confidentiality of Personal Information:
The use of a consumer report from an RIS under the proposed rule may conflict with state laws that protect the privacy of personally identifying information (PII) and limit the use of PII.

Read Veritec's 61-page response in its entirety

About Veritec Solutions
Veritec Solutions, LLC, founded in 2001, has established itself as the industry leader in real-time regulatory information systems and solutions. For over 15 years, they have implemented real-time technology solutions providing regulators across the globe with tools to protect consumers and promote healthy markets for regulated industries. Veritec has a proven track record of success in implementing “first-of-its-kind” regulatory information systems and is committed to delivering reliable, high-quality, customer-focused solutions. Visit Veritecs.com to learn more.

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Jaymie Kohl, Corporate Marketing
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