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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Threat that National Banks Could Help Predatory Lenders Charging 135% to 199% Apr to Evade New California Law

A coalition of 61 consumer, civil rights, and community groups sent letters to three federal bank regulators urging them not to allow their banks to help payday lenders evade state interest rate limits. The groups sent separate letters to the Federal Deposit Insurance Corp. (FDIC), which regulates the only banks currently involved in rent-a-bank schemes; the Office of the Comptroller...

Prohibiting Rent-a-Bank Arrangements: A Longstanding Banking Principle

Download this factsheet for more information on the top three principles against rent-a-bank arrangements: Long Precedent Against Rent-A-Bank Schemes Has Served Banks and Consumers Well. More Recent Rent-a-Bank Arrangements (with FDIC-supervised banks) Include Grossly Irresponsible Loans. Change in Course Would Invite Risk, Backlash, and Erosion of Confidence in Banking System.

Letter to CFPB on Payday Lending Rule Payment Protections

Consumer watchdog groups urged the U.S. Consumer Financial Protection Bureau (CFPB) to take action immediately to implement the payment provisions in its payday lending rule, whose compliance date is August 19, 2019. These provisions restrict payday and vehicle-title lenders from attempting to withdraw money from borrowers’ bank accounts after two attempts have failed, a practice that significantly harms struggling consumers...

Consumer and Civil Rights Groups Urge FDIC, OCC, and Fed to Prevent Bank Payday Loans

A coalition of national consumer and civil rights groups wrote letters to three top banking regulators – the FDIC, OCC and Federal Reserve – on the importance of preventing the reemergence of debt-trap bank payday loans. View the letter to the FDIC, letter to the OCC, and letter to the Fed. These letters were signed by Americans for Financial Reform...

Comment on CFPB's Proposed Repeal of the Payday Lending Rule

The Center for Responsible Lending (CRL), as part of a coalition of civil rights, consumer, and labor groups, submitted an official comment letter to the Consumer Financial Protection Bureau (CFPB), excoriating CFPB Director Kathy Kraninger’s plan to gut a 2017 CFPB rule that was issued to stop payday loan debt traps. The coalition’s comment letter, submitted on the last day...

Testimony: Ending Debt Traps in the Payday and Small Dollar Credit Industry

On April 30, 2019, the House Financial Services Committee’s Subcommittee on Consumer Protection and Financial Institutions convened a hearing on “ Ending Debt Traps in the Payday and Small Dollar Credit Industry.” Download the full written and oral testimony of CRL's Diane Standaert below: Download the full testimony. (PDF) Download the oral testimony. (PDF) Watch Diane Standaert's opening statement and...

Payday and Car Title Lenders Drain Nearly $8 Billion in Fees Every Year

Payday and car-title loans typically carry annual percentage rates (APR) of at least 300%. These high-cost loans are marketed as quick solutions to a financial emergency. Research demonstrates, however, that they frequently lead to debt that is nearly impossible to escape. In addition, these loans are related to a cascade of other financial consequences, such as increased overdraft fees, delinquency...

The Debt Trap of Triple-Digit Interest Rate Loans: Payday, Car-Title, and High-Cost Installment Loans

Although marketed as quick cash for financial emergencies, payday and car-title loans typically become long-term debt that drains hundreds of dollars—if not thousands—from consumers. These small dollar loans carry average annual percentage rates of 391% that make it very difficult to escape a cycle of debt that can last months or years. Either through direct access to borrower bank accounts...

Comments to the Consumer Financial Protection Bureau Proposed Delay of the Payday & Vehicle Title Rule

The organizations listed below submitted this comment letter to the Consumer Financial Protection Bureau (CFPB) on its new leadership’s proposed delay of a 2017 rule the agency had issued to stop payday and car title loans from trapping consumers in debt. The letter rebuts the CFPB’s rationale for proposing a 15-month delay of the payday rule, which the agency is...

Bill Analysis of Indiana SB 613: Consumer Credit

SB 613 increases the rates for existing consumer loans in Indiana, adds additional high-cost loan products to the marketplace, and significantly increases the rates that are considered to be criminal loan sharking. For each of these changes, lenders are provided extraordinary leverage over the borrower, are able to structure the loans in a way that incentivizes repeat re-borrowing, and are...
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