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3. Other Advantages and Costs

3. Other Advantages and Costs

Other benefits and costs that the Bureau would not quantify are discussed within the Reconsideration NPRM’s section 1022(b)(2) analysis in component VIII.E. These generally include ( but are not restricted to): the customer welfare effects related to increased usage of automobile name loans; intrinsic energy (“warm glow”) from use of loans which are not utilized ( and therefore wouldn’t be available beneath the 2017 last Rule); innovative regulatory approaches by States that could have now been discouraged because of the 2017 last Rule; public and private wellness expenses that will (or might not) result from payday loan use; modifications to your profitability and industry framework that will have took place a reaction to the 2017 last Rule ( ag e.g., industry consolidation which could produce scale efficiencies, motion to installment item offerings); issues about Start Printed web web web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or expenses to outside events from the improvement in access to payday advances; indirect expenses as a result of increased repossessions of cars as a result to non-payment of vehicle name loans; non-pecuniary costs connected with economic anxiety which may be eased or exacerbated by increased access to/use of payday advances; and any effects of fraud perpetrated on loan providers and opacity as to borrower behavior and history associated with a not enough industry-wide subscribed information systems ( ag e.g., borrowers circumventing loan provider policies against using numerous concurrent pay day loans, loan providers having more trouble pinpointing chronic defaulters, etc.).