At least two nationally chartered banks are offering their own version of payday loans, with high fees and short-term balloon payments similar to those that cause the typical payday borrower to become trapped in long-term debt.
Because the entire loan must be repaid in short order, borrowers are likely to have difficulty both retiring the loan and meeting their other obligations. As a result, these borrowers—like the typical customer of payday loan stores—will likely take out a series of back-to-back loans, staying indebted for a significant portion of the year.
The Office of the Comptroller of the Currency (OCC) is responsible for regulating these banks, and has so far failed to stop the predatory practice, making more Americans vulnerable to predatory short-term debt traps as it spreads.
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- Comment: To Department of Defense on Military Lending Act
Published: Feb 8 2007 Issue: Car Title Loans, Payday Loans
Comments on Military Lending Act submitted to Department of Defense by Consumer Coalition on Feb. 5, 2007.
- Small Loan CRA Comment
Published: Feb 2 2007 Issue: Car Title Loans, Overdraft Loans, Payday Loans
CRL Comment to the Federal Deposit Insurance Corporation on its proposed guidelines for affordable small-dollar loans.
- Comments: RIN 3064-AC95, Proposed Rulemaking on Federal Preemption
Published: Dec 13 2005 Issue: Payday Loans
The Center for Responsible Lending submits these comments on the proposed rules, ere part of a larger package of preemption rules urged upon the FDIC by the Financial Services Roundtable.
- FDIC's Revised Examination Guidance on Payday Lending
Published: Mar 14 2005 Issue: Payday Loans
Analysis of the FDIC guidance that stopped the "rent-a-charter" scheme that payday lenders were using to operate in states where they were illegal. FDIC issued strict guidelines under which their...