3. Other Advantages and Expenses

3. Other Advantages and Expenses Other advantages and expenses that the Bureau didn’t quantify are discussed within the Reconsideration NPRM’s part 1022(b)(2) analysis to some extent VIII.E. These generally include ( but they are not limited to): the buyer welfare effects connected with increased usage of car name loans; intrinsic energy (“warm glow”) from usage of loans that aren’t used ( and that wouldn’t be available underneath the 2017 last Rule); revolutionary regulatory approaches by States that will are discouraged by the 2017 last Rule; general public and private health expenses that will (or might not) result from payday loan use; modifications towards the profitability and industry framework that will have took place a reaction to the 2017 last Rule ( e.g., industry consolidation which could produce scale efficiencies, motion to installment item offerings); issues about Start Printed web Page 4304 regulatory doubt and/or inconsistent regulatory regimes across areas; advantages or expenses to outside events linked to the improvement in access to payday advances; indirect expenses due to increased repossessions of cars in reaction to non-payment of car name loans; non-pecuniary expenses related to economic anxiety which may be eased or exacerbated by increased access to/use of pay day loans; and any impacts of fraud perpetrated on loan providers and opacity as to borrower behavior and history pertaining to a not enough industry-wide authorized information systems ( ag e.g., borrowers circumventing lender policies against using numerous concurrent payday advances, lenders having more trouble pinpointing chronic defaulters, etc.). […]