This document discusses the importance of appointing a director to the Consumer Financial Protection Bureau (CFPB). It notes that while the Dodd-Frank Act established strong new consumer protections and the CFPB to enforce them, the CFPB cannot fully exercise its authorities without a director. This leaves gaps in oversight of non-bank financial institutions like payday lenders that interact with tens of millions of American families. Fully empowering the CFPB is critical to protecting consumers from predatory practices and ensuring the financial system supports economic growth and stability.
A Primer on the Amendments introduced in the U.S. House to undermine the creation of a much-needed Consumer Financial Protection Agency, in the Wall Street Reform and Consumer Protection Act.
Bank innovation - PwC Study on When the Growing Gets Tough: How Retail Banks ...Jeff Grill
As the United States emerges from the financial crisis, retail banks are striving to outperform their competitors while grappling with unprecedented regulatory challenges and shifts in consumer behavior. For more information see http://www.pwc.com/us/en/financial-services/publications/viewpoints/viewpoint-when-the-growing-gets-tough.jhtml
This paper is a summary of press clippings gleaned from Internet during the period April to July 2008. This exercise was performed to provide a quick summary of the US credit crisis at that particular point in time / 2nd quarter 2008. The paper was presented to a non native English speaking European audience consisting primarily of insolvency judges July 3rd 2008 in Paris.
A Primer on the Amendments introduced in the U.S. House to undermine the creation of a much-needed Consumer Financial Protection Agency, in the Wall Street Reform and Consumer Protection Act.
Bank innovation - PwC Study on When the Growing Gets Tough: How Retail Banks ...Jeff Grill
As the United States emerges from the financial crisis, retail banks are striving to outperform their competitors while grappling with unprecedented regulatory challenges and shifts in consumer behavior. For more information see http://www.pwc.com/us/en/financial-services/publications/viewpoints/viewpoint-when-the-growing-gets-tough.jhtml
This paper is a summary of press clippings gleaned from Internet during the period April to July 2008. This exercise was performed to provide a quick summary of the US credit crisis at that particular point in time / 2nd quarter 2008. The paper was presented to a non native English speaking European audience consisting primarily of insolvency judges July 3rd 2008 in Paris.
The Benefits of a Public Bank for New York State; the Derivatives explosion (nominal value of $1.2 quadrillion); The joint FDIC-Bank of England Proposal to forcibly swap deposits (incl. state deposits) for equity in a failing bank; The Public Banking model based on the Bank of North Dakota; The specific state bill for New York state; What the Fed can and can't (or won't) do to save municipalities
A View at the Financial Collapses in the United States and the Evolution of t...Joel Stitt
MBA Thesis presentation on United States Financial Collapses, specifically the Housing Market Crash of 2008 and the Great Depression, and the evolution of the banking and financial services industry over the past century
Investment banking project on Bank of America -Merrill LynchPankaj Gaurav
• Working model to serve the client
• Integrated operating model
• Lines of businesses
• Activities in global commercial banking
• Investment banking activities
• Details of advisory services in recent Deal in M&A, IPO issue
What is Strategy? Strategy Day at EO AcceleratorTim Hamilton
What is strategy? How are we going to grow top line revenue? Discover the "why" and "how" behind business strategy--what strategy is, and what strategy isn't.
PHP Australia is aimed at proficient developers, new developers and people who care about developers. Our events are all about working together to inspire each other to greater heights in our skill and share our passion for coding.
http://www.phpconference.com.au/
The Benefits of a Public Bank for New York State; the Derivatives explosion (nominal value of $1.2 quadrillion); The joint FDIC-Bank of England Proposal to forcibly swap deposits (incl. state deposits) for equity in a failing bank; The Public Banking model based on the Bank of North Dakota; The specific state bill for New York state; What the Fed can and can't (or won't) do to save municipalities
A View at the Financial Collapses in the United States and the Evolution of t...Joel Stitt
MBA Thesis presentation on United States Financial Collapses, specifically the Housing Market Crash of 2008 and the Great Depression, and the evolution of the banking and financial services industry over the past century
Investment banking project on Bank of America -Merrill LynchPankaj Gaurav
• Working model to serve the client
• Integrated operating model
• Lines of businesses
• Activities in global commercial banking
• Investment banking activities
• Details of advisory services in recent Deal in M&A, IPO issue
What is Strategy? Strategy Day at EO AcceleratorTim Hamilton
What is strategy? How are we going to grow top line revenue? Discover the "why" and "how" behind business strategy--what strategy is, and what strategy isn't.
PHP Australia is aimed at proficient developers, new developers and people who care about developers. Our events are all about working together to inspire each other to greater heights in our skill and share our passion for coding.
http://www.phpconference.com.au/
Make it Responsive! the logic, the code & tricks of tradeSidharth Sidharth
A talk on Responsive Web Design (RWD) for WordPress Themes for WordCamp Pune 2013. Talking about layouts, image optimisation, typography, media queries, viewport settings etc.
Data & Sustainability: How the Right Data Creates SuccessSightlines
Many sustainability officers are stretched thin by their duties, which includes a heavy workload of measuring and reporting data, both internally and externally. Despite this potential drawback, data is not the enemy of sustainability leaders. In fact, data and sustainability can go hand-in-hand as you build your case and outline opportunities for future improvements.
In this presentation, you'll learn:
- How data can help you overcome industry trends and make a difference on campus
- Ways data can build constituency around sustainability goals
- The value of verified data & peer context
- How reporting burdens can be eased
POZIVNICA
Pozivamo vas na predstavljanje života profesora Ivana Gudelja u ponedjeljak, 15. prosinca 2014. godine u 19 sati - Knjižnica i čitaonica Bogdana Ogrizovića. Preradovićeva 5, Zagreb.
Hrvatska udruga liječenih i oboljelih od hepatitisa “Hepatos” – Podružnica Grad Zagreb u okviru programa/projekta “Happy end – ipak postoji” financiranog iz sredstava Grada Zagreba, Gradskog ureda za zdravstvo, poziva Vas na predstavljanje života profesora Ivana Gudelja i knjige autora Blaža Duplančića: “Ivan Gudelj – hajdučka priča”.
This is an introductory presentation to the Farm Bill, put together with information from the Community Food Security Coalition and tailored for an audience in Worcester, MA.
Google Analytics: Configuring 10 Key Ecommerce MetricsPunit Kumar Tiwari
Meaningful analytics for eCommerce sites are different from, say, news sites. E commerce sites should track metrics that produce or prevent actual sales, after all. Which campaign generated sales? When did visitors abandon purchases? Which sites referred customers? Which product pages convert highly, and which do not?
Photos from Climbing Ben Arthur in Loch Lomond, ScotlandAncestral Chef
Photos from Climbing Ben Arthur (the Cobbler) in Loch Lomond, Scotland - majestic views of the mountains and the loch along with wildlife along the path.
Live Webinar: Crash Course to Marketing MetricsLinkedIn
Megan Golden, Senior Content Marketing Manager, LinkedIn
Amanda Halle, Senior Manager, Marketing, LinkedIn
Want to learn how to optimize how you measure full funnel impact? We've got you covered. The second webcast our Sophisticated Marketer's Webcast Series is our Crash Course in Metrics & Analytics and it's exactly what a data-driven marketer like you is looking for. We'll cover data accuracy, alignment, attribution challenges, and more to enable you to prove value.
Controlling the Growth of Payday Lending Through Local O.docxdickonsondorris
Controlling the Growth of Payday Lending
Through Local Ordinances and Resolutions
A Guide for Advocacy Groups and Government Officials
October 2012
Written By:
Kelly Griffith, Co-Director
Southwest Center for Economic Integrity
[email protected]
Linda Hilton, Director
Coalition of Religious Communities
Crossroads Urban Center - Utah
[email protected]
Lynn Drysdale, Staff Attorney
Jacksonville Area Legal Aid - Florida
[email protected]
Preface
Neighborhoods across America are witnessing the resurgence of predatory small loan operations.
In the last twenty years or so, payday lenders have exploited deregulated interest rates, won special
treatment from state legislatures, or designed products that slip through legislative or regulatory
loopholes. As a result, payday lending legally operates in 32 states, while 18 states either prohibit it,
curb it with rate caps, or have other restrictions that disrupt the payday loan business model costing
consumers as much as $7.46 billion a year in interest for over $44 billion in loans from both storefront
and online lenders. Payday loans cost cash-strapped borrowers triple- digit interest rates, trap borrowers
in repeat loans, foster coercive debt collection practices, and endanger bank account ownership for
families that live on the financial edge.
Payday lending has become increasingly controversial as the consequences of this defective
financial product have become painfully apparent. Payday lenders now outnumber Starbucks and
Burger King outlets across the country. Billions of dollars in usurious interest flows out of communities
to the national chain lenders. Mapping of payday loan locations by neighborhood characteristics and
studies of payday loan use issued by regulators and academics document that these high cost loans
disproportionately harm minority families and low to moderate-income borrowers. (For more
information, please visit Consumer Federation of America's www.paydayloaninfo.org)
Local leaders see the impact of payday lending on economic development, requests for financial
assistance, and financial distress in communities with high levels of low-to-moderate income and
minority families. While industry lobbying and campaign contributions have thwarted reform in many
state legislatures, local officials are taking action to stop payday lenders from exploiting their
neighborhoods by enacting restrictive zoning requirements and local ordinances.
Local policymakers interested in preventing predatory payday lending can also lend their support
to state-level reform efforts to cap annual interest rates at an all-inclusive 36 percent or repeal payday
loan authorization outright. As documented in North Carolina, reinstating small loan caps allows
responsible credit to flow, while saving consumers the billions of dollars now lost to predatory payday
lenders. Resolutions urging state legisla.
Consumer protections exist to prevent fraud, usury, extortion and other financial crimes. Since individuals are not always aware of commercial and legal details surrounding transactions and business communications, undesirable and underhanded access to the wallets and bank accounts of unsuspecting people becomes possible.
In response to the financial crisis of 2008, the Dodd-Frank Act included the creation of the Consumer Financial Protection Bureau (CFPB) to ensure that banks, lenders, and financial companies treat consumers fairly by providing greater protection and establishing rights to consumers of financial products. Is that purpose and role now in jeopardy?
Chapter 20Consumer Credit TransactionsL E A R N I N G .docxketurahhazelhurst
Chapter 20
Consumer Credit Transactions
L E A R N I N G O B J E C T I V E S
After reading this chapter, you should understand the following:
1. How consumers enter into credit transactions and what protections they
are afforded when they do
2. What rights consumers have after they have entered into a consumer
transaction
3. What debt collection practices third-party collectors may pursue
This chapter and the three that follow are devoted to debtor-creditor relations. In
this chapter, we focus on the consumer credit transaction. Chapter 21 "Secured
Transactions and Suretyship" and Chapter 22 "Mortgages and Nonconsensual
Liens" explore different types of security that a creditor might require. Chapter 23
"Bankruptcy" examines debtors’ and creditors’ rights under bankruptcy law.
The amount of consumer debt, or household debt1, owed by Americans to
mortgage lenders, stores, automobile dealers, and other merchants who sell on
credit is difficult to ascertain. One reads that the average household credit card debt
(not including mortgages, auto loans, and student loans) in 2009 was almost
$16,000.Ben Woolsey and Matt Schulz, Credit Card Statistics, Industry Statistics, Debt
Statistics, August 24, 2010, http://www.creditcards.com/credit-card-news/credit-
card-industry-facts-personal-debt-statistics-1276.php. This is “calculated by
dividing the total revolving debt in the U.S. ($852.6 billion as of March 2010 data, as
listed in the Federal Reserve’s May 2010 report on consumer credit) by the
estimated number of households carrying credit card debt (54 million).” Or maybe
it was $10,000.Deborah Fowles, “Your Monthly Credit Card Minimum Payments May
Double,” About.com Financial Planning, http://financialplan.about.com/od/
creditcarddebt/a/CCMinimums.htm. Or maybe it was $7,300.Index Credit Cards,
Credit Card Debt, February 9, 2010, http://www.indexcreditcards.com/
creditcarddebt. But probably focusing on the average household debt is not very
helpful: 55 percent of households have no credit card debt at all, and the median
debt is $1,900.Liz Pulliam Weston, “The Big Lie about Credit Card Debt,” MSN Money,
July 30, 2007.
1. Debt owed by consumers.
726
http://www.creditcards.com/credit-card-news/credit-card-industry-facts-personal-debt-statistics-1276.php
http://www.creditcards.com/credit-card-news/credit-card-industry-facts-personal-debt-statistics-1276.php
http://financialplan.about.com/od/creditcarddebt/a/CCMinimums.htm
http://financialplan.about.com/od/creditcarddebt/a/CCMinimums.htm
http://www.indexcreditcards.com/creditcarddebt
http://www.indexcreditcards.com/creditcarddebt
In 2007, the total household debt owed by Americans was $13.3 trillion, according to
the Federal Reserve Board. That is really an incomprehensible number: suffice it to
say, then, that the availability of credit is an important factor in the US economy,
and not surprisingly, a number of statutes have been enacted over the years to
protect consumers both before and a ...
Similar to Improving Americans' Financial Security: The Importance of a CFPB Director (20)
White House State of the Union 2016 - Enhanced GraphicsObama White House
On January 12, 2016, President Obama delivered his final State of the Union address to Congress and the nation.
Check out the slides from the enhanced broadcast of his address, featuring charts, graphs, and images that help explain the policies and issues he discussed.
Learn more at WhiteHouse.gov/SOTU.
President Obama penned a letter to Congressman Nadler of New York outlining how the Iran deal is a key piece of our strategy to help our allies in the Middle East counter Iran's destabilizing activities.
Abraham Lincoln (1809–1865). "Nicolay Copy," Gettysburg Address, 1863. Page 1 and 2. Holograph manuscript. Manuscript Division, Library of Congress. Gift of Hay family, 1916 (2.5). Courtesy of the National Archives and Library of Congress.
Message: Commemorating the 50th Anniversary of the White House FellowsObama White House
This is the President's message commemorating the establishment of the White House Fellows, a prestigious program dedicated to giving the nation’s most promising leaders insight into the inner workings of the Federal government. To learn more visit: http://www.whitehouse.gov/about/fellows.
The minimum wage helps support family incomes, reducing inequality and poverty, but as a slide deck from the Council of Economic Advisers shows, as the real value of the minimum wage has been allowed to erode, it has stopped serving this important purpose.
White House State of the Union 2014 Enhanced Graphics PosterObama White House
On January 28, President Obama delivered the 2014 State of the Union Address to Congress and the nation.
Check out the slides from the enhanced broadcast of his address, featuring charts, graphs, and images that help explain the policies and issues he discussed.
White House State of the Union 2014 Enhanced GraphicsObama White House
On January 28, President Obama delivered the 2014 State of the Union Address to Congress and the nation.
Check out the slides from the enhanced broadcast of his address, featuring charts, graphs, and images that help explain the policies and issues he discussed.
See more at WhiteHouse.gov/SOTU.
President Obama's Handwritten Tribute to the Gettysburg AddressObama White House
150 years after President Lincoln delivered the Gettysburg Address, President Obama penned a handwritten tribute to President Lincoln's historic remarks.
President Obama believes we have a moral obligation to lead the fight against carbon pollution. Share the details of his plan to help make sure people in your community get the facts.
Now Is the Time: President Obama's Plan to Reduce Gun ViolenceObama White House
The President’s plan to protect our children and our communities by reducing gun violence.
Learn More: http://www.whitehouse.gov/issues/preventing-gun-violence
President Obama is calling on Congress to make sure that taxes don’t go up on 98 percent of American families next year, as they are scheduled to do January 1, 2013. Learn more about his plan in this new infographic.
The Obama Administration recognizes that the interconnected challenges in high-poverty neighborhoods require interconnected solutions. The Neighborhood Revitalization Initiative is a community-based approach to help neighborhoods in distress transform themselves into neighborhoods of opportunity.
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new product—it signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
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Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the telegram id of my personal pi merchant who i trade pi with.
Tele gram: @Pi_vendor_247
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
The Evolution of Non-Banking Financial Companies (NBFCs) in India: Challenges...beulahfernandes8
Role in Financial System
NBFCs are critical in bridging the financial inclusion gap.
They provide specialized financial services that cater to segments often neglected by traditional banks.
Economic Impact
NBFCs contribute significantly to India's GDP.
They support sectors like micro, small, and medium enterprises (MSMEs), housing finance, and personal loans.
How to get verified on Coinbase Account?_.docxBuy bitget
t's important to note that buying verified Coinbase accounts is not recommended and may violate Coinbase's terms of service. Instead of searching to "buy verified Coinbase accounts," follow the proper steps to verify your own account to ensure compliance and security.
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
5. Measuring the Impact of Non‐Banks in the Lives of Americans4
Across the country, tens of millions of American families use non‐bank financial institutions for their
financial needs. Although these non‐bank institutions are often overlooked, they have a significant
impact on the everyday lives of American families.
Sometimes the relationship between non‐banks and consumers is undertaken knowingly and
voluntarily, but in many cases American consumers are largely unaware of their indirect (e.g., credit
bureaus) or perhaps involuntary (e.g., debt collectors) relationship with these institutions.
Highlighted below are some statistics that give a sense of the scale of non‐bank activities and their
impact.
Non‐Banks Affect the Lives of Millions of Americans.
o Roughly 200 million Americans rely on credit reporting agencies to report their credit
histories accurately when applying for mortgages, loans to purchase cars and other
goods, or credit cards to facilitate their daily financial transactions.5
o Studies estimate that nearly 20 million individuals use payday lenders.6
o More than 14% of consumers have one or more debts in collections.7
o Over 4 million Americans have used prepaid cards.8
Each year Non‐Banks Engage in Hundreds of Billions of Dollars of Transactions with American
Families.
o Some industry forecasts expect the total dollars loaded onto prepaid cards climbing to
$672 billion over the next few years, more than double the $330 billion put on prepaid
cards in 2009.9
o Industry estimates find that payday loans totaled more than $29 billion in 2010.10
Additionally, other studies estimate that every year payday lending costs Americans
$4.2 billion in high fees.11
o Debt collectors receive over $40 billion annually from third party collections.12
4
These numbers quantifying both the number of Americans affected and the amount of activity in each market are taken from a range of
sources at different times using different methodologies. In addition, many consumers engage in multiple types of non‐bank activities. As result
these numbers should not be aggregated and instead should be taken as illustrative of activity that exists in the non‐bank financial space.
5
Stuart Pratt. Comments of Consumer Data Industry Association (CDIA). “RE: Information privacy and innovation in the internet economy.”
CDIA to National Telecommunications and Information Administration.
6
Center for Responsible Lending. CRL Issue Brief. “A 36% APR cap on high‐cost loans promotes financial recovery.”
7
Federal Reserve Bank of New York. “Quarterly Report on Household Debt and Credit.”
8
Federal Deposit Insurance Corporation. “National Survey of Unbanked and Underbanked Households.”
9
Mercator Advisory Group. “Seventh Annual Prepaid Card Forecast.”
10
Stephens Inc. Industry Report. “Payday Loan Industry.”
11
King, Parris, and Tanik. Center for Responsible Lending. “Payday lending sinks borrowers in debt with $4.2 billion in predatory fees every
year.”
12
ACA International and Pricewaterhouse Coopers. “Value of Third‐party Debt Collection to the U.S. Economy in 2007: Survey and Analysis.”
4
6. A Deeper Look into Specific Areas of the Non‐Bank Sector
Payday Loans:
Payday loans offer short‐term funds at very high rates of interest (on average 400 percent according to
some studies13) that are not always clearly disclosed. The borrower typically writes a post‐dated personal
check in the amount he or she wishes to borrow plus a fee, in exchange for cash. The lender cashes the
check at the agreed‐upon date, which is usually the borrower's next payday. These loans are also called
“cash advance loans” or “check advance loans.” Borrowers in desperate need of cash may agree to
disadvantageous loan terms. The payday loan industry has grown significantly over the past decade.
Some reports indicate that nearly 20 million Americans use payday lenders.14 The payday
lending space is especially important as studies have found that payday lenders on average
charge fees of roughly $16 for a $100 two‐week loan.15 If borrowers miss payments these fees
can begin to accumulate resulting in extremely high total payments. Some studies have found
that as a result payday loan borrowers are paying nearly $4.2 billion in high fees annually.16
Payday loans can thus create a debt‐and‐fee‐spiral that some customers may find extremely
difficult to exit.
Payday loans are used more often by individuals with poor credit.17 In some cases their
financial resources have been depleted by an emergency, sustained unemployment, or family
illness. These individuals are particularly vulnerable to unfair payday lending practices.
The CFPB will also be able to establish federal supervision and oversight over payday lenders and larger
participants in other financial service markets. The CFPB’s full authorities will permit action to help
prevent unfair, deceptive, or abusive practices affecting the Americans, which frequently rely on non‐
bank financial institutions.
Money Services Businesses and Prepaid Cards:
Many consumers depend on non‐bank money services to meet their day‐to‐day financial needs. These
services include money transmitting, money orders and check cashing, which consumers may use to cash
their paychecks, pay their rent and utilities, or meet other routine and emergency financial needs.
Money transmitting is a significant money services business. It generally involves the receipt of funds by
a transmitter that then sends the funds to a recipient in another location on behalf of a consumer, for a
fee. Prepaid cards often serve as substitutes for a checking or a savings account for those that lack them.
13
King and Parrish. Center for Responsible Lending. “Springing the Debt Trap: Rate caps are only proven payday lending reform.”
14
Center for Responsible Lending. CRL Issue Brief. “A 36% APR cap on high‐cost loans promotes financial recovery.”
15
King and Parrish. Center for Responsible Lending. “Springing the Debt Trap: Rate caps are only proven payday lending reform.”
16
King, Parris, and Tanik. Center for Responsible Lending. “Payday lending sinks borrowers in debt with $4.2 billion in predatory fees every
year.”
17
Chatterjee, Goetz, and Palmer. “An Examination of Short‐Term Borrowing in the United States.”
5
7. There are many types of prepaid cards, including general purpose reloadable open‐loop payment cards,18
electronic benefits transfer cards,19 and payroll cards.
Money transmitting businesses are used to send funds internationally and domestically, often
for paying routine bills. One study estimates that total transaction volume for money
transmission could be over $70 billion.20
Prepaid card products affect a large number of consumers. Industry estimates find that the
prepaid card business involves over $330 billion21 with millions of individuals having used these
cards.22 Some industry forecasts expect the prepaid card business to grow to $672 billion over
the next few years. 23
Independent Non‐Bank Mortgage Lenders and Servicers:
Independent non‐bank lenders originate, close, and fund loans using sources of funds other than bank
deposit capital. Servicers manage payments on performing loans and work through options for
addressing distressed homeowners.
Many of the largest subprime lenders during the housing bubble were independent non‐bank
mortgage bankers who were not federally supervised. During the run‐up to the financial crisis,
independent non‐bank mortgage bankers were amongst the largest originators of subprime
mortgages.24
Default rates on subprime loans originated during the bubble are often much higher than
prime loans: The cumulative default rate on subprime mortgages made in 2006, when the
housing bubble reached its height, now exceeds 50 percent. Prime loans of the same vintage
were less than 10 percent.25
Debt Collectors:
Debt collectors are in the business of recovering money owed on delinquent accounts. Many debt
collectors are hired by companies that are owed money by consumer debtors; debt collectors often
operate for a fee or for a percentage of the total amount collected.
18
An open‐loop card usually carries the logo of a major payment network, such as American Express, Discover, MasterCard, or Visa, and can be
used wherever those cards are accepted.
19
Electronic benefits transfer cards are made available by the federal government and by state and local governments to allow individuals to
access government benefits such as Social Security or unemployment compensation.
20
KPMG. “2005 Money Services Business Industry Survey Study.”
21
Mercator Advisory Group. “Seventh Annual Prepaid Card Forecast.”
22
Federal Deposit Insurance Corporation. “National Survey of Unbanked and Underbanked Households.”
23
Mercator Advisory Group. “Seventh Annual Prepaid Card Forecast.”
24
Inside Mortgage Finance. 2011 Mortgage Market Statistical Annual.
25
Standard and Poors. “U.S. Residential Mortgage Default Index: Defaults Are Waning But Cumulative Default Rates Remain Extremely High For
Recent Vintages.”
6
8. Debt collection is a multi‐billion dollar industry. About $1.2 trillion of consumer debt is
currently delinquent, with $834 billion seriously delinquent (at least 90 days late).26 Debt
collectors received over $40 billion from American consumers for third party collections.27
While collection activities can create economic and social value, they can also be a source of
abuse. Personal hardships such as divorce, family member death, illness or job loss are often the
precursors to a household falling behind on debt payments. These consumers may lack the
resources to protect themselves from predatory collection behavior. According to the FTC, 27
percent of all complaints received pertain to the debt collection industry.28 Of the complaints
against collectors under the Fair Debt Collection Practices Act (FDCPA), nearly 50 percent cited
harassment.29
Credit Bureaus:
A credit bureau is an agency that collects and maintains individual credit information and sells it to
lenders, creditors, and consumers in the form of a credit report. Credit bureaus receive consumer credit
information from banks and other businesses. When another business with a "permissible purpose"
requests to see a credit report, the credit bureau sells it to them.
Most Americans have credit files. The major consumer credit reporting agencies maintain credit
files on over 200 million adults. These Americans rely on credit reporting agencies to report their
credit histories accurately when they apply for mortgages, loans to purchase cars and other
goods, or credit cards to meet their day to day needs.30 Many consumers have filed complaints
to the FTC regarding errors in these reports.
There can be differences between credit scores sold to consumers and scores used by lenders
to make credit decisions. Consumers who are unaware of the variety of credit scores available
in the marketplace may purchase a score believing it to be their “true” score. The most
significant adverse impact on a consumer from score differences would likely occur if the credit
scores the consumer buys give a substantially different impression of his or her credit risk than
credit scores that a lender would use.
The current system involves several different actors, all governed by the Fair Credit Reporting
Act (FCRA): Credit bureaus, which collect and sell credit information; furnishers of information
to the credit bureaus, such as creditors and debt collectors; and lenders, who use consumer
reports. Effective oversight requires authority over all the actors that make up the system.
26
Federal Reserve Bank of New York. “Quarterly Report on Household Debt and Credit.”
27
ACA International and Pricewaterhouse Coopers. “Value of Third‐party Debt Collection to the U.S. Economy in 2007: Survey and Analysis.”
28
Federal Trade Commission. “Federal Trade Commission Annual Report 2011: Fair Debt Collection Practices Act.”
29
Ibid.
30
Stuart Pratt. Comments of Consumer Data Industry Association (CDIA). “RE: Information privacy and innovation in the internet economy.”
CDIA to National Telecommunications and Information Administration.
7
10. The Impact of Non‐Bank Financial Institutions’ Practices on Specific
Communities
As discussed earlier, non‐bank institutions have a significant footprint in the lives of many Americans.
Below are some of the problems that members of specific communities have confronted when dealing
with non‐bank institutions.
Service members
The Problem: After receiving their first steady paycheck, enlisted service members are often
lured into easy credit offers. According to the Department of Defense, nearly 50 percent of
enlisted Service members are under the age of 25, often lacking experience in managing
finances, and without a cushion of savings to help them through emergencies.31Even older
military members often move to new locations where they may be unfamiliar with local
financial institutions and susceptible to deceptive marketing practices. Installment loan
companies often have offices near military bases and market their loans online exclusively to the
military. The Department of Defense found that the cost of loans was often not disclosed on
installment lender sites and annual rates ranged from 391 percent to 782 percent APR for two‐
week installment loans.32
How the CFPB will help: Without a Director, the CFPB will not be able to establish robust federal
supervision over key non‐bank financial service providers, such as high cost lenders and debt
collectors. With a Director, the CFPB will be able to combat practices by non‐bank actors that
harm consumers, helping our service members to avoid hidden fees and keep more money in
their wallets.
Older Americans
The Problem: In some surveys, one out of every five Americans over the age of 65 have
reported to be victimized by financial scams.33 Financial abuse directed towards the elderly is a
growing threat to the economic security of our country’s senior citizens.
How the CFPB will help: When it can exercise its full authorities, the CFPB will, for the first time,
provide ongoing federal oversight of both non‐bank companies and banks in the mortgage
market, and protect borrowers from unfair, deceptive or abusive lending practices regardless of
the type of lender. Older Americans also take payday loans, and the CFPB’s full authorities will
include examining payday lenders to ensure compliance with federal consumer financial laws.
31
Department of Defense. “Report on Predatory Lending Practices Directed at Members of the Armed Forces and Their Dependents.”
32
Ibid.
33
Investor Protection Trust. “Elder Investor Fraud Survey.”
9
11.
Students
The Problem: According to a National Endowment for Financial Education poll of young people
aged 22 to 29 years old, survey respondents with debt indicated that having debt had influenced
important decisions, including causing them to delay or not pursue further education (29
percent), to take a job they would not otherwise have taken (22 percent), or to move in with
parents or other relatives (19 percent).34
How the CFPB will help: With its full authorities, the CFPB will be able to supervise private
student lenders, fight unfair lending practices, and require lenders within its jurisdiction to
follow the rules.
Latinos
The Problem: Of the Latino households that send international electronic transfers
(“remittances”) to Latin America, many use a remittance company to do so. In recent years,
more than one‐in‐three Latinos say they sent remittances.35 Many of these consumers are
unfamiliar with the terms and conditions of the remittance or its fees. Studies have also found
that 36 percent of payday loan borrowers in California were Latino‐Americans and 34 percent of
borrowers in Texas were Latino‐Americans, as well.36
How the CFPB will help: The CFPB has the authority to issue a regulation requiring important
disclosures to remittance customers, but it needs its full authorities to examine remittance
providers for compliance with current law and future regulations. With its full authorities, the
CFPB will be able to establish, for the first time, federal oversight over the larger participants in
a market such as certain companies that provide money transfer services to consumers, and will
enforce new protections for certain remittances, including requirements to provide consumers
easy‐to‐understand, pre‐transactional pricing disclosures and receipts.
34
National Endowment for Financial Education. “Young Adults’ Finances Poll.”
35
Pew Center. “Hispanics and the Economic Downturn: Housing Woes and Remittance Cuts.”
36
Center for American Progress. “A Word of Caution on Payday Loans.”
10