The CFPB recently revealed details about proposals it is considering to stop what it characterized as payday “debt traps,” targeting payday loans, deposit advance products, vehicle title loans, and certain high-cost installment and open-end products – a scope of rulemaking so comprehensive it threatens to push a number of lenders out of the small-dollar lending market entirely. “[T]he contemplated rules are sweeping. We believe that, if they are adopted, the rules will lead to many lenders exiting the business of making covered loans and radically contract consumer access to covered loans,” Jeremy Rosenblum, a partner in the Philadelphia office of the Ballard Spahr law firm, said in a recent client note. The proposals under consideration cover both short-term and longer-term credit ...