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The absence of lender underwriting enabled by the two defining characteristics of a covered longer-term loan mean that there is often little or no relationship between the payments under a loan and the financial capacity of the particular consumer who takes the loan.
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Regulatory intervention without clear evidence of risk or careful consideration of the consequences to consumers is a bad precedent and contrary to the policy objective of the prudential regulators.
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The SBA guarantee acts as second-level protection for the bank.
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See FTC Policy Statement on Unfairness, Int'l Harvester, 104 F.
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Bankwest is a division of Commonwealth Bank of Australia, which is the product issuer unless otherwise stated.
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The timeframe for the consideration of benefits and costs includes the initial transitional period during which lenders would develop the capacity to comply with the proposed regulation and the market would adjust to the new requirements and limitations of the proposal, as well as the steady-state that would be reached once those adjustments had occurred.