Policy & Legislation

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 90D+ delinquency (DQ) rate on loans insured by the Federal Housing Administration (FHA), which captures loans that are 90 or more days delinquent but not in foreclosure or bankruptcy, has increased sharply. At 3.57% in September 2025, it has since risen to 5.23% in January 2026, an increase of 1.66 percentage points (pp) in just 4 months. Market commentators...

The Military Lending Act (MLA) provides protections for active-duty service members and their families, including a 36% interest rate cap. This one-pager examines how payday loan apps, often marketed as Earned Wage Advance, attempt to evade these protections by claiming they are not loans. It also highlights a growing body of court decisions rejecting those claims and recognizing these products...

The Department of Veterans Affairs (VA) holds 25% of the risk of loss associated with borrower default on VA-guaranteed mortgages. Therefore, VA has an economic interest in directing mortgage servicers to engage in risk management techniques that will reduce the number of defaults on VA-guaranteed loans that transition to disposition (i.e., foreclosure, short sale, or deed-in-lieu of foreclosure) and cause...

Nadine Chabrier, CRL Senior Policy Counsel, teamed up with Molly Gallagher, Statewide Poverty Action Network Policy Lead, to talk to Washington state representatives about the importance of examining BNPL policy during the affordability crisis. Watch the full video to see Molly Gallagher's presentation and more.

Payday loan app companies try to evade state credit laws by promoting a legal fiction: they claim that these loans are not loans. As state regulators and attorneys general investigate and challenge industry violations of credit law, these lenders have lobbied state legislatures for exemptions from those laws. This state law chart serves as a shorthand guide to state regulation...

Payday loan apps draw borrowers into a pattern of repeated borrowing and a succession of fees that pull from already-stretched paychecks, creating demand for the next loan.

In 2025, the Department of Education and Congress reshaped the student loan system through new laws, administrative actions, and proposed rules that could bring further changes. Together, these actions mean higher costs, fewer protections, and more uncertainty for millions of borrowers. Here is what is happening and how it could affect borrowers. Download the full factsheet. CRL Advocacy Priorities Protect...

Watch the full testimony from Jaylon Herbin, Director of Federal Campaigns as he argues for strengthening the Public Service Loan Forgiveness (PSLF) program.

Consumer installment loans offered by nonbank lenders can be an expensive form of credit that keeps borrowers in costly long-term debt. Lenders offer these loans to individuals for their personal or household use. Consumers borrow between $1,000 to $25,000 or more. Many states regulate the costs and other terms of these loans, usually requiring them to be repaid monthly over...