Payday and Other Small Dollar Loans

Payday, car-title, and similar high-cost loans, typically with interest rates of 100% APR and higher, trap people in crippling long-term debt. CRL advocates for regulators to require lenders to verify borrowers can afford to repay a loan before that loan is issued. CRL also advocates for interest rate caps of no higher than 36% APR and for enforcement of current usury laws.

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Payday loan apps, often marketed as Earned Wage Access (EWA) products, present themselves as innovative alternatives to storefront payday lending. In practice, they function much the same way, by charging steep fees, encouraging repeat borrowing, and reducing future paychecks. Consumers primarily use payday loan apps to cover ordinary, recurring expenses like rent, groceries, and utilities rather than occasional emergencies, and...
The Center for Responsible Lending submitted this letter-for-the-record focused on opposition to H.R. 7866, a bill that would override state authority to block 100%+ APR loans issued by banks and through rent-a-bank schemes. The legislation was considered as part of a House Financial Services Committee hearing entitled “Strengthening the American Economy: Promoting Growth, Opportunity and Prosperity” and held on September...
The Center for Responsible Lending submitted feedback to the New York State Department of Financial Services on the final Buy Now, Pay Later (BNPL) Regulations (the new 3 NYCRR 423 and amendment to 23 NYCRR 101) in order to highlight the ongoing consumer harms that key elements of the regulations address, offer suggestions to improve the existing regulations and affirm...
H.R. 7866 would slash a key protection against high-cost lenders. The bill eviscerates state-law interest rate limits on loans, which are the only such limits that exist for almost all Americans. H.R. 7866 would end states' ability to enforce their own interest-rate limits on loans made to their residents by out-of-state, state-chartered banks. The result would be more financial distress...
The 118 undersigned consumer, civil rights, and community organizations write to urge you to defend and strengthen interest rate limits and transparency to address the affordability crisis by: Insisting that the Trump Administration deny applications from Enova and OppFi, lenders that charge annual interest rates of 100% APR and higher, to become national banks; Opposing H.R. 7866 (Davidson)/S. 3889 (Moreno)...
The Center for Responsible Lending (CRL) and National Consumer Law Center (NCLC) filed an amicus brief supporting Oregon’s authority to enforce its interest-rate protections against loans made to Oregon residents by out-of-state, state-chartered banks. The case, National Association of Industrial Bankers, et al. v. O’Day, concerns House Bill 4116, legislation that overrides the federal interest-rate preemption provisions of the Depository...
A broad coalition filed comments urging regulators to deny the application of the predatory lender Opportunity Financial (“OppFi”) to acquire a national bank. If the deal is approved, OppFi could offer loans up to 195% APR, and payday loan apps carrying even higher interest rates, in every state. The Federal Deposit Insurance Corp. (FDIC), Office of the Comptroller of the...
The Center for Responsible Lending (CRL) strenuously objects to the merger application of OppFi, Inc. and BNCCORP, Inc. to merge into OppFi National Bank. The FDIC should refuse to approve that application on the grounds that it significantly fails to meet statutory factors under the Bank Merger Act. If the FDIC is not persuaded on the face of the application...
The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) filed an amicus brief supporting Colorado’s authority to enforce its interest-rate limits against out-of-state state-chartered banks and their non-bank lending partners when they make loans to Colorado residents. These arrangements, known as “rent-a-bank” schemes, can result in loans carrying rates approaching 200% APR. The case, National Association...
CRL joined 225 labor, consumer, civil rights, and community organizations in sending a letter opposing H.R. 9330, the misnamed Earned Wage Access Consumer Protection Act, which exempts earned wage payday loans from the Truth in Lending Act (TILA), the Military Lending Act, the Equal Credit Opportunity Act, and other federal laws. The bill preempts state laws that protect people from...
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