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 market for personal loans is massive and growing, yet the fintechs and other non-bank lenders who make such loans are not subject to regular oversight by the Consumer Financial Protection Bureau (CFPB), which has “created an unlevel playing field and a large risk to consumers,” write the Consumer Bankers Association (CBA) and the Center for Responsible Lending (CRL). The...
On July 8, the Center for Responsible Lending, California Reinvestment Coalition, Consumer Federation of California, National Consumer Law Center, Public Law Center, and UC Berkeley Center for Consumer Law & Economic Justice filed an amicus brief in Los Angeles County (California) Superior Court in Opportunity Financial v. Hewlett. Opportunity Financial v. Hewlett addresses the legality of Opportunity Financial’s “rent-a-bank” scheme...
From the introduction to the comment: Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low income clients), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB...
The exploding market of Buy Now Pay Later (BNPL) credit demands the same level of oversight that we give to credit cards. BNPL can help some borrowers spread out their payments, but entails real risks and costs, which is not clear in advertisements highlighting interest-free payments and “no impact” on credit scores. Regulation is necessary to protect consumers from hidden...
A broad coalition of bank and credit union associations and consumer organizations submitted a letter to the U.S. House Committee on Financial Services urging passage of the bipartisan Close the ILC Loophole Act. The bill would help prevent more companies from running what is essentially a bank without the necessary regulatory oversight.
The group letter begins: The undersigned 77 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations appreciate the opportunity to comment on the CFPB’s inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas. We welcome the CFPB’s recent inquiry into Affirm, Afterpay, Klarna, PayPal, and Zip, however...
In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers...
Payday lenders often describe the cost of their loans in terms of fees or simple interest rates. Responsible lenders readily disclose the APR on their loans, aligned with the Truth in Lending Act (TILA). They are not afraid to let their customers compare the costs of their loans to other loans in the market. Tellingly, payday lenders often object to...
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