The payday industry's "new" guidelines are already proven failures. Any reliance on them for legislative reforms will also fail. In states that have legislated these guidelines, the debt trap persists. Nearly two of every three loans still go to borrowers with twelve or more loans per year and less than one percent of transactions use the "mandatory" payment plan. The only proven solution to stop the payday debt trap is to enforce a state's two-digit usury cap.

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