October 29 2026

ABA: Error in Credit Calculation in CFPB’s Proposed Payday Loan Rule

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The CFPB's proposed payday loan rule provides a method to calculate the total cost of credit used to determine whether a loan would be a “covered loan.”  In a comment letter, the ABA observed that the proposal incorrectly calculates the total cost of credit for open-end credit as though a line of credit’s annual fee is paid monthly. The ABA shows that the total cost of credit in the CFPB’s example would be 13.25%, rather than the CFPB’s calculated 68.26%. [1/24/17]

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