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Lenders that do not already have a records system in place would need to incur a one-time cost of developing such a system, which may require investment in information technology hardware and/or software.
Regardless of whether state law characterizes these transactions as loans, they are considered extensions of credit for purposes of federal consumer protection law.
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In particular, the Bureau invites comment on whether this proposed exception is too broad and includes some transfers that should be subject to the payment disclosure.
We understand the helpless feeling can be harsh, and that is why we provide these types of loans to borrowers, there are many things we cannot control, and things can happen unexpectedly, but we are here to help.
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The Bureau solicits comment on whether this definition is appropriate in the context of this proposal and whether any additional guidance on the definition is needed.