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October 2022 Advocacy Newsletter
Summary:
As to the Department of Finance’s consultation on predatory lending and the criminal rate of interest, the Council believes it is more appropriate to set the criminal rate of interest based on a floating benchmark rate plus a maximum allowable spread rather than solely through a fixed interest rate ceiling. To protect consumers from egregious loan terms, the Council believes it would be helpful to require a consistent interest calculation methodology that does not penalize prepayments or effectively charge interest on interest, as well as a workable cooling-off period. Our full summary is below for those interested.