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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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...
Payday loan apps, often marketed as Earned Wage Access (EWA) products, present themselves as alternatives to storefront payday lending that help promote financial inclusion. In practice, they function much like traditional storefront payday lenders, worsening wealth and income disparities by charging steep fees, encouraging repeat borrowing, and reducing future paychecks. Our research shows that the average APR for loans repaid...
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...
The 103 undersigned consumer, civil rights, and community organizations wrote to Chairman Scott, Ranking Member Warren, Chairman Hill and Ranking Member Waters urging them 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...
This litigation tracker compiles key cases addressing payday loan app products. It highlights how courts and enforcement authorities are analyzing core issues such as whether advances constitute “credit,” how fees and tips are treated under applicable law, and whether these products trigger protections like the Military Lending Act’s 36% rate cap and other disclosure and anti-evasion requirements. So far, every...
The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) continued with their advocacy on behalf of payday loan app users in the courts, filing an amicus (friend of the court) brief in the Ninth Circuit Court of Appeals to support Staff Sergeant John Revell's individual claims and on behalf of putative classes against Grant Money, LLC...
Civil rights and consumer advocacy organizations urge the Federal Reserve Board to deny an application to become a bank holding company, submitted by Enova, raising particular concern about the effects of its predatory lending on communities of color. This nonbank lender has disproportionate number of complaints from majority-minority communities, charges triple-digit interest rates, has charge-off rates (a measure of defaults)...
CRL submitted comments to Acting Director Vought arguing the draft Strategic Plan retreats from the Bureau's statutory obligations at a moment of acute consumer affordability pressure, raising 3 core concerns: Fair banking is defined too narrowly. Objective 1.1 centers almost entirely on ideological debanking under EO 14331, with no mention of ECOA, fair lending, or the racial wealth gap. Objective...
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