Authors

Brandon Rusk

Document Type

Case Summary

Publication Date

9-23-2021

Case Synopsis

Nevada Revised Statutes (NRS) § 604A.5074(1) regulates title loans and limits the duration of the original term to 30 days. NRS § 604A.5074(3) extends the permissible duration up to 210 days if the title loan meets the requirements outlined in the subsection. A specific requirement delineated in the subsection is that 210-day title loans cannot be subject to any extension. NRS § 604A.065 defines extensions. Here, the Nevada Supreme Court held that the extension prohibition on the 210-day title loans includes refinances based on the plain language of NRS § 604A.065.

Furthermore, NRS § 604A.5076(1) limits a title loan amount to the “fair market value” (FMV) of a secured vehicle. The Nevada Supreme Court held that the FMV limitation only refers to the principal amount of the loan and does not include interest and other costs and fees.

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