CFPB Under Attack Again by PDL, Banks, Credit Union Trade Groups

By | Dec 8, 2016

Congress Attacks All Planned CFPB Rules

Jer Trihouse

Jer Trihouse

By: Jer Ayles-Trihouse. Financial, fintech, banking and credit union trade groups are storming Congress to  repeal all upcoming CFPB [Consumer Financial Protection Bureau] rules governing arbitration, payday lending, debt collection and prepaid cards by using its authority under the Congressional Review Act.

All of us in the payday loan, installment loan, short term loan and car title loan industry are fully aware that the CFPB is about to finalize several rules, including arbitration, small dollar, third-party debt collection prepaid cards… having a deleterious and ultimate choke hold on consumers, the economy, and balance sheet lenders.

It’s time for Congress and President Trump to implement their authority under the Congressional Review Act (CRA) to blow-up these threats by the CFPB!

Meanwhile, we’re all forced to spend HUGE amounts of MONEY and Time dealing with CFPB rules that will likely NEVER SEE THE LIGHT OF DAY!

The structure of the CFPB has been determined to be unconstitutional by a federal D.C. Court!

So, let’s get back to serving the desires of the millions of borrowers who VOTE for payday loans, title loans, small dollar short term loans demonstrated by their DAILY USE OF OUR FINANCIAL PRODUCTS, and allow us to continue to develop new loan products at reduced rates and fees for our clients.

The CFPB is already a dinosaur that stifles competition, destroys consumer ability to make choices that fit their own unique financial situation and puts millions of dollars in the pockets of lawyers, consultants and lobbyists RATHER than allowing balance sheet lenders to focus on providing outstanding service at fair rates!

The future of our small dollar, short term lending industry has not looked this bright in a LONG TIME. There is still tremendous opportunity for “mom-and-pops,” venture capitalists, hedge funds, and vendors such as loan management softeare companies, ACH/ICL/DEBIT providers, tribes, money transfer system conduits… to enter and SERIOUSLY PROSPER in our industry!

Excited? Wnat to learn more? Need help? Got a question? Jer@TrihouseConsulting.com 702-208-6736

Finally, to receive future updates from us, simply plug in your First Name and your email address. Then click on the “Subscribe Link” that you’ll shortly receive in your Inbox. No Spam and no Garbage. Spam is for jerks and we are not jerks!

Now go make some $$. Jer Trihouse

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Bank Accounts for Payday Loan Lenders

By | Nov 28, 2016
By: Jer Ayler at Trihouse Consulting

Payday loan lenders and micro-lenders continue to suffer from “bank discontinuance” issues as a result of “Operation Choke Point” launched by the Obama administration in August 2013.

The Community Financial Services Association of America (CFSA) and Advance America said ” a preliminary injunction was needed to end the back-room campaign of coercion by the Federal Reserve, the Federal Deposit Insurance Corp, the Office of the Comptroller of the Currency, the CFPB [ruled unconstitutional by a D.C. Court]  and competitors masking themselves as so-called consumer protectionists.”

U.S. regulators are collaborating in an attempt to stop banks from offering banking services to micro-lenders in an effort to force consumers in need of emergency funding to beg, borrrow or steal when facing financial stress.

Nearly 50% of U.S. residents are unable to access $400 cash [Link to Federal Report] when faced with the need to fix their car to continue working, purchase a medical prescription for their child or a family member, turn on their heating or electricity…

Payday lenders, istallment lenders and additional small dollar lenders requested a federal judge for immediate relief! 

Jer Ayles-Ayler Trihouse Consulting

Jer TrihouseConsulting

The survival of mom and pop loan businesses is at stake!

It’s rumored that the big, multi-billion dollar online Fintech lending companies – SOFI, Lending Club, Prosper, Marcus, Avant, Enova… are adding additional pressure to wipe-out the small dollar lending industry; including the small independent store owners.

Advance America said its own situation became dire after five banks decided in the last month to cut ties, including a 14-year relationship with U.S. Bancorp, “putting it on the verge of being unable to maintain a bank account.”

The small lender national association injunction requests the federal court to “order the agencies to cease and desist from harming the reputations of Advance America and other CFSA members; from applying pressure on banks, encouraging them to terminate relationships with the banks and other CFSA members; denying CFSA members access to financial services; and from depriving members ability to pursue business.”

Instead of eliminating the “bad apples” of the payday industry, the agencies have “set about to choke off the life-sustaining financial oxygen that the entire industry, and millions of under-banked individuals, depend on.”

The CEO for CFSA, Dennis Shaul, stated that the results of Operation Choke Point for the payday loan, installment loan and micro-lending industry has been “dire.”

Mr. Shaul says that U.S. Bank has dropped its affiliation with several members, including Advance America, allegedly putting the company “on the verge” of being unable to maintain a bank account.

Another example by CFSA is thata smaller payday lender, DollarSmart Money Centers,  was forced to close when it lost all its banking services.

Here’s a link to the Injunction by the CFSA vs. the FDIC

Here’s a link to the Original Request

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Payday and Title Loan Requirements

By | Oct 18, 2016

Typical Criteria Required to Apply for a Payday Loan, Installment Loan, or Car Title Loan

Jer Trihouse Payday Loan Industry ResourcesThis is a list of fairly typical requirements of consumers to qualify for a loan. These criteria are dependent on the state the borrower resides in, the status of the lender [startup, seasoned…]…

Payday Loan/Installment Loan:

  • Valid ID/DL
  • Proof of Income
  • Debit Card {No temp cards}
  • Completed Loan Application
  • Pass credit reporting agency filters
  • Military Exemption
  • Reside in state having enabling payday loan legislation
  • References 3

Title Loan:

  • Valid ID/DL
  • Titled Vehicle
  • Title – Lien Free {Co-signors?}
  • Valuation – 50% Rough Value/Salvaged 20% Rough Value
  • Proof of Residency – Utility Bill/Lease/Mortgage Statement
  • Proof of last payroll amount
  • Completed Loan Application
  • Completed Vehicle Evaluation Sheet
  • Military Exemption
  • Cell phone statement {make copy}

Click this link to get the “Bible” on “How to Start a Payday Loan or Title Loan Company.”

How-Start-Car-Title-Pawn-Business

Payday Loan Franchise?

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Bedford Texas City Ordinance: Payday Loan Stores

By | Oct 15, 2016

 

A Typical Texas Payday Loan City Ordinace

ORDINANCE NO. 16-3183

AN ORDINANCE OF THE CITY OF BEDFORD, TEXAS SETTING FORTH REGISTRATION

REQUIRMENTS AND CREDIT EXTENSION GUIDELINES FOR CREDIT ACCESS BUSINESSES;

CONTAINING A SAVINGS CLAUSE; PROVIDING A PENALTY CLAUSE; AND PROVIDING AN

EFFECTIVE DATE.

WHEREAS, the City of Bedford, Texas is a home rule city acting under its Charter adopted by the

electorate pursuant to Article XI, Section 5 of the Texas Constitution and Chapter 9 of the Local

Government Code; and,

WHEREAS, the City of Bedford, Texas contains credit access businesses, which provide payday

loans and advances to consumers who work and reside within the City; and,

WHEREAS, the City Council of the City of Bedford has determined that certain credit access

businesses engage in abusive and predatory lending practices, offering easy money to those

members of our community who are in a tight spot with onerous terms and fees; and,

WHEREAS, the practices of certain credit access businesses cause members of our community to

become trapped in a cycle of short term, high interest loans resulting in large debt and huge

payments; and, Continue Reading >>

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CFPB Takes Broadside- Leadership Structure Ruled Unconstitutional!

By | Oct 11, 2016

CFPB Leadership Structure Ruled Unconstitutional by D.C Circuit Court :-)

This just in from Ben Lane:

“In a unanimous decision of the three justices of the United States Court of Appeals for the District of Columbia Circuit, the court ruled that the CFPB’s current structure allows the director to wield far too much power, more than any other agency in the government.”

‘Because the Director alone heads the agency without Presidential supervision, and in light of the CFPB’s broad authority over the U.S. economy, the Director enjoys significantly more unilateral power than any single member of any other independent agency,’ the court writes.

And it gets worse for the CFPB.

“From the court’s decision:By “unilateral power,” we mean power that is not checked by the President or by other colleagues. Indeed, other than the President, the Director of the CFPB is the single most powerful official in the entire United States Government, at least when measured in terms of unilateral power. 

That is not an overstatement. What’s this mean  for the Payday Loan Industry?

What about the Speaker of the House, you might ask? The Speaker can pass legislation only if 218 Members agree. The Senate Majority Leader? The Leader needs 60 Senators to invoke cloture, and needs a majority of Senators (usually 51 Senators or 50 plus the Vice President) to approve a law or nomination. The Chief Justice? The Chief Justice must obtain four other Justices’ votes for his or her position to prevail. The Chair of the Federal Reserve? The Chair needs the approval of a majority of the Federal Reserve Board. The Secretary of Defense? The Secretary is supervised and directed by the President. On any decision, the Secretary must do as the President says. So too with the Secretary of State, and the Secretary of the Treasury, and the Attorney General.

In short, the court writes, the director of the CFPB is the “single most powerful official in the entire U.S. Government, other than the President,” in terms of unilateral power.

Email TrihouseConsulting for a PDF of the Original D.C. Court Decision: Original Article Put “DC Circuit in Subject.”

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