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Payday and Other Small Dollar Loans

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 Rent-A-Bank Scheme

Wednesday, September 4, 2024

The Rent-A-Bank Scheme

The Problem High-cost lenders are ignoring state law and continuing to lend high above the state's legal interest rates, using a practice called Rent-A-Bank. In some cases, these rates are under 36% on very large loans. In others, rates are in the triple-digits, charging consumers up to 200% to finance car repairs, furniture, and even puppies. How Rent-A-Bank Works In...
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Policy & Legislation
Payday and Other Small Dollar Loans

Comment: Paycheck Advance Loans Are Credit Products and Should Be Subject to Federal Disclosure Requirements

Friday, August 30, 2024

Comment: Paycheck Advance Loans Are Credit Products and Should Be Subject to Federal Disclosure Requirements

The Center for Responsible Lending, the National Consumer Law Center, and Consumer Federation of America commend the CFPB for affirming that paycheck advance loans, regardless of their characterization by lenders, are credit products subject to federal disclosure requirements. As written, the proposed interpretive rule by the Consumer Financial Protection Bureau regarding the applicability of the Truth in Lending Act (TILA)...
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Comment Letter
Payday and Other Small Dollar Loans

165 Consumer Advocacy, Faith Based, Racial Justice, Community Advocacy Groups, Workers’ Rights, and Academics Support the CFPB’s Paycheck Advance Interpretive Rules

Thursday, August 29, 2024

165 Consumer Advocacy, Faith Based, Racial Justice, Community Advocacy Groups, Workers’ Rights, and Academics Support the CFPB’s Paycheck Advance Interpretive Rules

The consumer, labor, civil rights, legal services and community organizations wrote with strong support of the Consumer Financial Protection Bureau’s proposed interpretive rule on emerging paycheck advance products, sometimes marketed as “earned wage” products.
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Comment Letter
Payday and Other Small Dollar Loans

Comment on the Consumer Financial Protection Bureau’s Buy Now, Pay Later (BNPL) Interpretive Rule

Thursday, August 1, 2024

Comment on the Consumer Financial Protection Bureau’s Buy Now, Pay Later (BNPL) Interpretive Rule

The Center for Responsible Lending submitted a comment to the Consumer Financial Protection Bureau on their interpretive rule regarding Buy Now, Pay Later (BNPL) digital user accounts.
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Comment Letter
Payday and Other Small Dollar Loans

90 Consumer, Civil Rights, and Community Organizations on the CFPB Buy Now, Pay Later Interpretive Rule

Thursday, August 1, 2024

90 Consumer, Civil Rights, and Community Organizations on the CFPB Buy Now, Pay Later Interpretive Rule

These organizations support the CFPB’s conclusion that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic statements and disclosures. Those protections will enhance the safety of BNPL credit and make it easier for consumers to manage their finances.
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Comment Letter
Payday and Other Small Dollar Loans

Earned Wage Advance: States Should Regulate As Credit, Protect Consumers

Friday, May 10, 2024

Earned Wage Advance: States Should Regulate As Credit, Protect Consumers

Earned or Early Wage Advance (EWA) products offer workers access to their wages before payday, usually for a fee. While low-wage workers can benefit from EWA programs that are properly designed and regulated, they can instead be harmed when products are allowed into the marketplace without guardrails keeping their use and cost within reasonable bounds. States should regulate all EWA...
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Policy & Legislation
Payday and Other Small Dollar Loans

Coalition Opposing Earned Wage Access Consumer Protection Act (HR 7428)

Monday, April 15, 2024

Coalition Opposing Earned Wage Access Consumer Protection Act (HR 7428)

The 193 labor, civil rights, consumer, legal services and community groups and academics joined in this letter to express opposition to the draft Earned Wage Access Consumer Act. In the guise of offering protections, the bill obscures its true effect: to exempt fintech cash advances from the Truth in Lending Act, to endorse a form of loan that makes workers...
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Letters to Congress
Payday and Other Small Dollar Loans

Not Free: The Large Hidden Costs of Small-Dollar Loans Made Through Cash Advance Apps

Wednesday, April 3, 2024

Not Free: The Large Hidden Costs of Small-Dollar Loans Made Through Cash Advance Apps

Consumers who took out small loans using cash advance apps paid triple-digit annual interest rates, experienced high levels of repeat reborrowing, and incurred more bank overdraft fees.
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Research
Payday and Other Small Dollar Loans

Coalition Opposing the Financial Services Innovation Act of 2023 (HR 7440)

Wednesday, February 28, 2024

Coalition Opposing the Financial Services Innovation Act of 2023 (HR 7440)

This legislation purports to provide a safe harbor for financial innovation, but too often, “innovation” is synonymous with a lack of meaningful safeguards for consumer financial products. Creating these regulatory “sandboxes” for companies would force agencies to shirk their statutory duties to enforce the law and protect consumers and instead prioritize allowing risky and unproven products into the marketplace before...
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Letters to Congress
Mortgage Lending Payday and Other Small Dollar Loans

Stop High-Cost Lenders from Evading State Laws: An Overview of Rent-a-Bank Schemes & the Simple DIDMCA Opt-Out Solution

Thursday, November 30, 2023

Stop High-Cost Lenders from Evading State Laws: An Overview of Rent-a-Bank Schemes & the Simple DIDMCA Opt-Out Solution

In the 1990s payday lenders partnered with banks to create a practice known as Rent-a-Bank. This practice exploits a provision of federal law that allows banks to export their interest rates across the country, ignoring state laws meant to protect borrowers from abusive high-rate lending that can lead to a debt trap. While predatory lenders originally used store-front payday locations...
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Policy & Legislation
Payday and Other Small Dollar Loans

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Building on Over 40 Years of Lending Experience

CRL’s expertise gives it trusted insight to evaluate the impact  of financial products and policies on the wealth and economic stability of Asian, Black, Latino, rural, women, military, low-wage, low-wealth, and early-career workers and communities.

CRL is an affiliate of Self-Help, one of the nation’s largest nonprofit community development financial institutions. Our work leverages the strength of partnerships with national and local consumer and civil rights organizations.

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