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But we also need to recognize that loan products which routinely lead consumers into debt traps should have no place in their lives," Cordray said.
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Nevertheless, if such lenders elect to initiate payment transfers from consumers' accounts when—as the lenders know or should know—the accounts lack sufficient funds to cover the amount of the payment transfers, they could assess the consumers substantial fees permitted under the asset account agreement (including NSF and overdraft fees) as well as any late fees or similar penalty fees permitted under the loan agreement for the covered loan.
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