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Commentary by Eamonn K. Moran

In a partially redacted Order in a "Supervisory Designation Proceeding," the CFPB determined that it has supervisory authority over an installment lender after concluding that the lender met the legal standard for supervision under the Consumer Financial Protection Act.

An FDIC Credit and Consumer Products Survey suggests that risk is increasing in the industry, "as reflected by more frequent reports of credit concentrations, increases in potentially volatile funding sources, and more out-of-area lending."