The Consumer Financial Protection Bureau is working towards more clearly defining the term "abusive" in the Dodd-Frank Act. Mick Mulvaney announced plans for definition in the Bureau's rulemaking agenda, but he did not specify a timeline for the decision.

However, Ballard Spahr Partner Chris Willis said, "While a definition to the term "abusive" may add clarity to the sector, it will likely have minimal impact on lenders' operations." Instead Mr. Willis suggests that the CFPB's "recent mention of possible rulemaking related to the disparate impact doctrine would be far more valuable."

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