By Jer with Trihouse Consulting ~ The tribe payday loan business model has been around since at least the late 1990′s. In the “early days,” individual tribe members collaborated with lenders to circumvent state and province usury and licensing requirements. Although this rendition of the tribe sovereign model is no longer employed, there still remains outstanding litigation and regulatory challenges that continue. The Martin Web and Western Sky controversies are part of this ongoing story.
Western Sky has always described itself as “wholly owned by an individual member of the Cheyenne River Sioux Tribe;” not by the tribe or any of its political subdivisions. It refers to itself as a Native American-owned business operating within the exterior boundaries of the reservation, a sovereign nation within the U.S.
Western Sky Financial, “located” on the Cheyenne River Reservation Timber Lake, S.D., has said it was not required to follow Maryland law because of tribal immunity, according to the Maryland Department of Labor, Licensing and Regulation.
The Maryland labor department’s Division of Financial Regulation said Thursday it has issued a final cease and desist order against Western Sky, its owner Martin Webb and other related parties. The order also prohibits the company from collecting or attempting to collect on any loans made to Maryland consumers. The company has the right to appeal the final order to Maryland Circuit Court, said Mark Kaufman, commissioner of financial regulation.
With the aid of Wall Street and sophisticated tribe legal counsel, the payday loan industry has evolved significantly since the early days of what was once referred to as “the rent-a-tribe model.” Much like the gaming industry, there are today, legal methods and strategies available that enable geographically challenged tribes lacking sophisticated resources to collaborate with “capital” and expertise in serving the millions of consumers who want and need small dollar loan products to help them solve their temporary, short-term financial challenges.
By Jer Trihouse: Raj Date, a former director of The CFPB has formed a consultancy to focus on bank sponsored payday loan/small dollar loan products. He’s quoted as saying, “Is it a product that is expensive because it can be? Because overdraft sets a price umbrella, and traditional payday sets a price umbrella,” so banks say, ” ‘Whatever, just a little bit lower than that.’ But that doesn’t mean that pricing won’t come in if there’s competition.”
In the piece at American Banker, Mr. Date goes on to say, “Developing a better short-term loan is “the single most promising thing” in the portion of the consumer financial industry that serves low-income and other financially underserved customers.”
In essence, Mr. Date states that he thinks banks are simply charging more than they need to. Banks have the luxury of having a “captured customer, access to more credit data decisioning tools, superior marketing tools and lower fraud costs and a much lower cost of capital.” (He’s certainly correct regarding his last point! Banks can access capital from the Fed for less than 1%!) “So, there is nothing about the product that isn’t cheaper than the alternatives, overdraft and traditional payday.”
There’s just one point Mr. Date fails to acknowledge. A bank cannot compete with a nimble, entrepreneurial enterprise employing the multitude of credit decisioning tools already available to small dollar lenders, employment of social media, 24/7 loan proceed delivery channels, smart phone web site presence and most importantly, the millions of relationships we small dollar loan providers already enjoy with our customers.
Read the entire American Banker piece here: EX-CFPB Director launches Payday Loan Consultancy
Store operators in the payday loan business, car title lending, cash for gold, BHPH, etc. don’t get this: YOU MUST figure out the mobile marketing challenge you face TODAY. Customer’s are “looking” for you on their phones. If your biz looks like crap on their phone, you just lost another customer!
I’m NOT suggesting you invest $1000′s of bucks on a “full-on” mobile friendly web site that processes customer applications, captures their bank acct. info, nabs their SS#… Hell, today, store owners don’t even need a traditional website! Go check out a company FOCUSED on building phone friendly websites for our industry. It’s $200 one-time!
What’s one customer worth to you? Just enable a customer to FIND you on their phone and “click-to-call” your store or find your location on Google Maps!
Get started at EZMobileToday.com This is a “no-brainer!” Enable your next customer to call, email or text your store.
And call to thank me when you get that new customer! I’m serious!! Jer – Trihouse
Don’t Give Up On Email.
Yeah sure, we’re huge fans of serving our customers via traditional websites, mobile websites, blogs, TV, radio, direct mail… If you’re a Lender or a Vendor, you’d better be using all these channels to compete.
Email? Many of our clients have been discounting email lately. Everything they hear and read is focused on mobile, social and text messaging. Knuckleheads who pontificate about the decline of email “open rates” and “don’t have a dog in the hunt” discourage building your brand and “touching” your customers via email.
HOGWASH! Build your LIST. Lead your clients to your website, your Facebook page, your Twitter account…Train your employees to capture your customer’s contact info; EVERYTHING! And DON’T FORGET to share ALL YOUR company info as well.
The message? Don’t give-up on email. Let your client choose what works best for them. Allow your client to embrace you as tight as they like )
Hello All – as of Monday 5/27 the Regular Session of the 83rd Texas Legislature closed. As you may know, there were no Credit Access Business bills passed and regulations remain the same as they were prior to the Session. A “Special Session” was called and there are only a handful of topics reported to be up for discussion, namely Redistricting.
Going back to February when our group became involved, we have learned much about how the process works in Austin, and also understand first hand that smaller Credit Access Businesses can make a difference. The small business owner-operator/entrepreneur in Texas has a lot to say, and fortunately for us we had an audience this Session with many Representatives and Senators at the Capitol who listened.
We now have some breathing room and freedom to operate without concern of implementing the long list of regulations & rules we saw proposed in many bills this Spring. However, the concern over local City Ordinances remains, and our group should remain mobilized and informed about how we can work against the spread of these burdensome and impractical restrictions.
Our group has the opportunity to prepare for next Session which begins January 2015. We’ll need to work against City Ordinances as mentioned, and also now it will be wise to address many of the issues we saw brought up by industry opponents, such as: “Cycle of Debt,” Income thresholds for loan amounts, refinance limits, and extended payment plans. Planning ahead and staying focused on what we know our opponent’s arguments might be in 2015, will serve us well in the future.
Efforts are underway to finalize an operator Compliance/Education/PR Program that will hopefully command the attention of Lawmakers, Regulators, and Consumer Advocates, and accomplish the objective of getting our Industry ahead of the curve next time around. Updates on the progress of this program, called Borrow Smart, will be sent out when available with a possible roll-out date in July 2013.
It’s Miro P. from Payday Loan University
You haven’t invested in my “Powerhouse PDL Operator’s Course” yet and I wanted to share a few comments that have already been said about my course:
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“A lifetime of experience and knowledge in PDL operations and marketing, boiled down into simple ‘a la carte’ strategies anyone can use. The survey and examples alone, are well worth the price of admission. If you’re running a PDL store, do whatever you can to get your hands on this course, devour it and IMPLEMENT.” Steve Bartlett- Vero Beach, Florida
“Miro, good in-the-trenches stuff in your collections and underwriting chapters. It’s a business in which you have to get your hands dirty.” Steve Hodgdon -Mr. Collections – Novato, California
As a reader of PaydayLoanIndustryBlog, you have a very limited opportunity to invest in Miro’s Powerhouse PDL Operator’s Course at a heavily discounted price. I only emailed this ALERT to entrepreneurs that I firmly believe will achieve SUBSTANTIAL benefits by studying AND executing the new tactics revealed. You know I respect my subscribers and do not waste their time. Jer Trihouse
Act NOW, and take advantage of the special price that I worked out for you, and you ONLY. Sorry! It’s too late. The $200 special discount Miro was offering to Trihouse readers ended . No B.S. The Powerhouse Course went to $595.00. (It’s still a great value at $595.00.)
You’ll get 180+ pages revealing:
- A completely new way to look at underwriting
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***All of this is 100% guaranteed. If you’re disappointed with the quality of the material, you get your money back!
P.S. Ironically, some of the most compelling testimonials I’ve received from the hundreds of readers of the Powerhouse PDL Operator’s Course are in regards to the way the Course is written. “It’s blunt, clear and funny.” Our business is so unique. It’s exciting to see one of the most creative and innovative people in our industry “pry open his head, and let us peek inside to see what we can use.”
P.P.S: DUE TO DEMAND, “Powerhouse PDL Operator’s Course” is now available printed & shipped or immediate download it in Adobe Acrobat!
Now go make some money!!
Jer – Trihouse
With few exceptions, the media and so-called consumer advocacy groups do a pathetic job of reporting on the payday loan industry! At least they’re consistent; their bias makes me gag. The old saying, “If you say it enough times, it becomes the truth” is their strategy. For your “enlightenment” Dear Reader, a quote and a link to another feeble attempt to attack our small dollar loan industry: “Citizens Advice Bureau received 1270 survey responses (out of 4.1 million UK loans). Selected results, covering some of the main issues for consumers such as how much the loan is going to cost and how it needs to be repaid, are set out below.” A link to the “Survey???”
If you don’t own and operate at least one payday loan store, stop reading NOW! My friend and collaborator, Miro Posavec, a Co-Founder of PaydayLoanUniversity.com and CEO at TotalOperationsManagement has written a brand new PDL Course for store operators. Take a look… Miro is offering a limited time, serious discount to followers of Trihouse Consulting. AGAIN, this is NOT for NEWBIES! “Seasoned” PDL operators ONLY!
EXPOSED: Secrets that you can use to increase your storefront payday loan business
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What tools and strategies do online lenders use to give loans to customers that they’ll never meet or see in person? How do they lend money when they’ll never see a Drivers’ license, paystub, or bank statement?
This information is the real deal with nothing held back. Marketing, underwriting, collections, employee relations, THEFT prevention, and bad debt. It’s all in there. And sometimes it’s not pretty.
My Powerhouse Course offers killer strategies for payday owners to grow their business through MEASURED marketing. You will see how the “tricks” the Online lenders use can benefit you.
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AND, I’m going to teach you how to HOLD onto those dollars by preventing employee theft, reducing bad debt, and be more effective at collections.
The Payday industry is very different. If you want to learn the strategies you need to have the business you dream of and hold every single dollar you spend accountable for multiplying itself then Powerhouse is the resource for you.
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And here it is, plain and simple: If at any time you’re dissatisfied, simply return the information for a prompt
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So, let’s look at my product offering and How you can save big $$$ if you order NOW!
1: Powerhouse Storefront Operations Course:
My 180+ page guide to Marketing, employee relations, and enhanced operations.
List Price of this course: $595.00 But if you order by midnight Wednesday May 22, 2013, Trihouse has a deal on this course for: $395.00. That’s a $200 savings.
This week only, Trihouse & Payday Loan University is offering this SPECIAL DISCOUNT: $395.00 IF you invest in my Powerhouse PDL Operator’s Guide NOW. That’s a total savings of $200.00!! That’s more than 33% OFF the full list price. You must act by midnight Wednesday May 22, 2013 – NO B.S – this price will never be offered again!!!
Why should you act right now? There is no RISK! All of my courses are 100% guaranteed to be useful, practical, and include PROVEN strategies and ideas. Again, these DISCOUNT prices are only available until midnight Wednesday May 22, 2013. When these courses are officially released, these discounts will never be seen again! (I swear on my name and on my reputation!)
Co-founder Payday Loan University
Total Operations mngt.