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Processor marketing materials, Bureau staff conversations with industry, and documents made public through litigation indicate that the NACHA unauthorized return and total return rate thresholds have already prompted migration to remotely created checks and debit network transactions, both of which are not covered by the NACHA rules.

Second, the Bureau believes that an off-ramp provision likely could not be designed in a way to ensure that consumers actually receive the off-ramp.

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Second, the Bureau inquired as to whether the proposals under consideration would increase the SERs' cost of credit.

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(ii) A covered short-term is the second loan in the sequence if the consumer has a currently outstanding covered short-term loan, or if the consummation date of the second loan is within 30 days following the last day on which the consumer's first loan in the sequence was outstanding;

to post on or distribute through the website any information that would be in breach of another person’s intellectual property rights.

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