February 4, 2021
Payday and Other Small Dollar Loans
Policy & Legislation
Predatory lenders are making loans of 100% APR or more in states with limits of 36% or less by laundering loans through an out-of-state bank that is not subject to state interest rate limits. This is a rent-a-bank scheme.
Will these schemes make payday and high-cost lending legal everywhere? How can we protect our state interest rate limits? Why is this so important right now?
CRL Resources
- April 23 Webinar - Time Running Out: Congress Should Repeal Rule Protecting Predatory Lenders Harming Small Businesses, Veterans, Consumers
- Correcting the Record: The OCC’s “Fake Lender” Rule Expands Harmful, Predatory Lending
- One Pager: The OCC and FDIC Plan to Trample State Laws by Gutting the Longstanding “True Lender” Doctrine
- Poll: Dangers of Rent-a-Bank Schemes "Two-thirds of voters (66%) are concerned about the ability of high-cost lenders to arrange loans through banks at rates higher than the state laws allow."
- Testimony: Rent-A-Bank Schemes and New Debt Traps
- Factsheet: Industrial Loan Company Charters Pose Risks to Consumers and the Economy: A Moratorium Is Needed
- Factsheet: Predatory Lenders’ Rent-a-Bank Scheme: What Is It and What Can We Do To Stop It?
- Factsheet: Prohibiting Rent-a-Bank Arrangements: A Longstanding Banking Principle
- Sign-on Letter: 120 Consumer, Civil Rights, Community Groups Oppose HR 4439 and Sham Rent-a-Bank Payday Lending
- Two pager: Rent-a-Bank Bill Could Open the Floodgates to Predatory Lenders: S1642 & HR3299
Statements
- Faith Leaders Call for Repeal of OCC Rule Blessing “Rent-a-Bank” Schemes
- Statement from the National Association of Federally-Insured Credit Unions
- Statement from the Conference Of State Bank Supervisors
- OCC Issues Final "True Lender" Rule that would Help Fraudulent, Predatory Loan Schemes (Oct 28)
- Advocates Condemn FDIC Rule that Encourages Predatory High-Cost Loans through Rent-A-Bank Schemes (Jun 25)
- Advocates Condemn Rent-a-Bank Rule that Encourages Predatory High-Cost Loans; Call on Congress to Pass Federal 36% Interest Rate Cap Limit (May 29 )
- Advocates Condemn Rent-a-Bank Rule that Encourages Predatory High-Cost Loans; Call on Congress to Pass Federal 36% Interest Rate Cap Limit (Feb 10)
- CRL Federal Campaign Director Testifies Before House Committee on Rent-A-Bank Schemes (Feb 7)
- CRL Federal Campaign Director Testifies Before House Committee on Rent-A-Bank Schemes (Feb 7)
- https://www.responsiblelending.org/media/advisory-house-committee-hearing-predatory-lending-rent-bank-schemes-feature-crl-nclc (Feb 6)
- Consumer and Civil Rights Groups Urge Federal Banking Regulator to Stop Rent-a-Bank Payday Loan Schemes (Jan 22)
Webinar Recording
