Evaluating the cost of credit and comparison shopping in the modern credit environment can be a daunting task, even for the most sophisticated shoppers. Lenders increasingly unbundle the costs of their loans from the interest rate into an array offees, outsource their overhead to third parties who add to consumers' costs, and unveil amazingly complex loan products that dazzle and confuse borrowers. At the same time, the preemption of state usury and consumer protection laws by Congress and the federal banking agencies has spurred deregulation at the state level. Today, the consumer credit marketplace is governed almost exclusively by disclosure rules. The subprime mortgage crisis of 2007 resulted from allowing the market to police itself and from the failure of disclosure to curb abuses.

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