Michael Dunn
Analyst · Vincent Caintic, Macquarie
Yes. I mean, obviously, Don spoken to you a little bit about this, but obviously the CFPB, I am not in a way to call it a proposal, but they came out a few weeks ago pre-proposal I guess is the way to maybe frame it. We got a lot of attention from everybody in our industry and including us. And we have included conversations in-house, most of conversations at the board trying to figure out if we can tell what the impact might be. But as I mentioned in my remarks, opening up, we think that very early stages and we have talked to outside counsel as well and very early stages of where the CFPB is in terms of rule-making. And it’s hard to say from what they put out a few weeks ago, what direction that it will ultimately take. Their initial focus as I mentioned was really on the ability to – those vendors who focus on the ability to repay or focus on ability to access customer accounts and not on lenders like us who do mostly underwriting for all of our products. And as I mentioned, we don’t have access to our customer accounts and through the ACH or equivalents. And so not sure how this will play out, we think it’s premature. We don’t think we have tried to assess what we think might be the impact. And again, with knowing specifically how it ultimately will play out, it’s hard to guess at it, but we don’t think and again we are just sort of guessing at this, we don’t think it will have much of an impact for us. And if it does have any kind of impact in any of our products, we also think that since we do underwrite all of our loans that we might have to make modifications, but those modifications won’t be big overhauls, but slight tweaks of the current processes we have. As it relates to how it will impact other people who are more directly affected by these preliminary rules, not clear, but we are also looking at that and we will be paying attention to that and there could be some opportunities for us. But again, premature, first, we have to figure out how it plays out. And we were – we have talked to some folks and we have talked to some folks about the timeline. And some people who were in the government or some people with the CFPB before think that at best this is a couple of years out and there will be lot of give and take between the CFPB and the industry between now and then. And so we will be watching it and making sure that we know what’s going on and making sure I understand the impact to us as it becomes clear, but at this point, just too early to tell.