Hope for helping the prospective payday loan customer

12/17/19
Short term (payday) loans and high interest consumer installment loans
continue to deplete low income households of micro dollars and their
communities of macro dollars. Although the CFPB seems intent on supporting
the depletions, a good number of states have provided some relief. 
Even in states without interest rate limitations
there are a couple of ideas that can help.

Chris Peterson and Nathalie Martin have provided legal support
to a movement to help consumer advocates convince municipalities
to enact ordinances that assist around the edges even though State
constitution and federalism block them from more meaningful reform.
A good number of local jurisdictions have enacted ordinances which
range from requiring a fee and a city license, to more restrictive
zoning and providing a list of alternatives and putting up signs that
make the borrowers more aware of what they are signing up for.
Most of these are aimed at payday lenders and
title lenders but a few are expanding to consumer installment loans.
Although these restrictions are minor, these efforts help build
anti-predatory lending coalitions.   The simpler and more to scale effort has to do with employer
based alternative lenders that provide such loans on a more responsible
installment repayment basis. In the past few years several business
models have emerged, but they depend on the employer making them
available under their “employee assistance” plans or the like.
There are two basic models; the installment loan model such as
TrueConnect, and the wage advance models of Payactiv and a host of
others. TrueConnect and Payactiv offer a free series of budget counseling.
The installment loan model with lower interest rates appears
sound and well regulated. These provide loans of between $1000 and $2000
with payment at more reasonable rates and fees and payable in installments,
usually over a year. The wage advance model is helpful for
very small loan amounts, but is unregulated in most jurisdictions
and has several concerns. First, a number of bait and switch entries
are not what they appear and if the employees borrow or takes an advance
for any significant percentage of their normal wages it is nearly impossible
for them to repay from their next paycheck. Many borrowers take multiple
wages advances each year. A center at Washington
University in St. Louis is studying these issues
https://socialpolicyinstitute.wustl.edu/items/workforce-financial-stability-initiative/
People at Pew Trusts and NCLC and CFE Fund are watching carefully
and with insight.
There is NO downside to an employer making responsible installment loan models
available and there are enormous benefits to both the employer
and the employees, yet the levels of participation of employers are still
much too small.








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