Oppose SB2306 / HB3192 – Rate Cap Loophole

Resource Overview

SB 2306 and HB 3192 would insert the TILA Loophole into the Predatory Loan Prevention Act. The TILA Loophole would allow lenders to charge an unlimited amount of hidden fees in the form of add-on fees and products like credit insurance. Under a TILA APR, there is no limit to what a lender can charge for add-on products and fees, allowing predatory lenders to continue charging excessive fees including unwanted and unnecessary add-on products and costs.

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