24. For consumer loans that allow for a MAPR in excess of 36%, is the Applicant and/or its Affiliates required to meet all of the other consumer loan characteristics?

Yes. If any of the consumer loan products (including credit cards and purchased loans) of the Applicant or its Affiliates allow for a MAPR in excess of 36%, each of the following standards must be met as well:

• the loans must have an annual default rate less than 5%;
• the loans in question may not include a leveraged payment mechanism;
• any such loans of $1,000 or less may not have repayment timeframes that exceed 12 months;
• for a period of 12 full months after the issuance of any such loan, the Applicant must waive any upfront fees for any refinance or new loan issued to the same borrower;
• any fees associated with such installment loans must be spread evenly over the life of the loan or pro rata refundable in the event of early repayment (including through a refinance); and
• all payments on any such installment loans must be substantially equal and amortize smoothly to a zero balance by the end of the loan term.

An Applicant that fails to meet all of the listed standards, in combination with a consumer loan product that allows for a MAPR in excess of 36%, will be disqualified.