THE BLOG

29
Aug

Rent a Tribe Schemes, Fintech Objections & the Logic Behind Them

Rent a Tribe Payday Loan Companies

[Let us know if you ever have any questions. TrihouseConsulting@gmail.com  Jer]
“Those who oppose the idea of American Indian tribes operating successful businesses that compete with non-tribal rivals sometimes use offensive terms to create the illusion of nefarious conduct. One of the ugliest assertions is that a tribe’s success occurs by “renting” itself to non-tribal members, who abuse it for iniquitous purposes.”

“The term “rent-a-tribe” originated in gaming, where attacks started as soon as tribes became a competitive threat to non-tribal casinos. Opponents suggested that tribes’ practice of hiring capable vendors to provide services related to casino operations was akin to “renting” sovereignty and detracted from the tribal ownership of the business, even though many non-tribal entrepreneurs engage in identical outsourcing practices when starting a new business in a regulated industry.”

The term “rent-a-tribe” grossly misrepresents American Indians, their intellectual abilities, and business acumen.

American Indian tribes are sovereign; they have the inherent authority to govern themselves free from outside interference. Sovereignty is acknowledged by the federal and state governments through treaties, laws, executive orders, and intergovernmental agreements, and confirmed by centuries of U.S. Supreme Court and…

Read More: The Times Herald

Want to learn how to launch a consumer loan business? Internet lending? Store-front lending? Licensing? Need to talk to an expert? Step-by-step procedures for “how to lend money to the masses.” Visit: The Business of Lending to the Masses

For a complete set of tribal lending documents: Tribe Lending Entities 5th item down on this page.

How to Start a Consumer Loan Business: Installment lending, car title loan lending, payday loan lending, personal loan business

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22
Aug

Texas CAB-CSO Payday Loan Model Under Attack

Texan consumer groups focus on upcoming CAB/CSO credit access businesses such as payday lenders to make their views known to Texas Sunset Commission

The Texas Fair Lending Alliance urged Texans to contact the Sunset Commission before Aug. 29, when the group meets regarding the Texas OCCC. This  office oversees licensing for Texas credit access businesses [CAB – CSO], including payday and auto-title lenders.

The Texas Fair Lending Alliance is a coalition of 60 consumer organizations.

“Texas Appleseed and United Ways of Texas referred to “Sunset review”—a process established to hold state agencies accountable by periodically evaluating whether they should continue to exist—offers opportunities to strengthen consumer protection against what they consider predatory lending.”

Texas CAB’s and their customers must prepare to support the continued existence of appropriate regulations to assure continued access to small dollar loans in Texas for those borrowers with no where else to turn!

Already, approximately 45 cities have adopted city ordinances placing limits on the number of times payday loans can be rolled over and paid in installments, and to require that proceeds from any renewal payments apply toward reducing the original loan principal.

The Texas Legislature should seek to preempt city ordinances and allow the expansion of new, competitive loan products and services. When you need $300 to fix your car in order to keep your job, where do you go for fast, no-hassle cash?

Already, online payday loan lenders such as Elevate, Avant, Speedy… are taking away market share and jobs from local, established Texas store-front lenders. This reality hurts commercial landlords and tax revenue as well.

Here come the online tribal lenders.

Shut down the loan stores helping consumers who reside in Texas and the tribe lending entities [TLE] will continue to take market share as well. I get a dozen calls every day from consumers who need an immediate loan – that’s CASH in their hands – NOW. They do not want to wait 2 – 5 days for their payday loan proceeds to “appear” in their bank account. Online lenders are still slow and clunky.

The Texas Sunset Commission includes five state senators, five members of the Texas House of Representatives, and two members of the public appointed by the lieutenant governor and speaker of the house.

Comments? Questions about “the business of lending money to the masses?” Email TrihouseConsulting@gmail.com

 

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15
Aug

This is Probably a Bad Idea… I Own a Payday Loan Company.

A Seriously Savvy, Experienced Payday Loan Lender Answers Direct Questions About the “Business of Lending Money to the Masses!”

[Jer Trihouse: To be clear, this is not my work! I just discovered this Q & A on an old Thread. Also, you’ll quickly figure out that this payday loan lender has navigated ALL the hoops, challenges and costs of securing a state license. So… like any of us who use the state licensing model, WE HATE TRIBAL LENDERS.]

YOU WANT TO READ THIS!

Whether you’re a lender, a collector a borrower, a scrubber, a loan management software company, a state licensed or tribal lender… YOU WILL LEARN FROM THIS! [Lender Resources]

Question: Do you have trouble sleeping at night?

Payday Lender: Not even slightly!

Q: OK, what are some ways I, as a loan holder, can avoid getting super screwed by the exorbitant interest rate?

Payday Lender: Pay the whole goddamn thing off NOW and never take another loan out from me.

Q: My plan, but sometimes you’re in a hard place, and these guys are the only option. But I totally agree.

Payday Lender: Is it online/tribal? Do they show their lending license? If its tribal, stop paying. Then send a letter saying you will only pay 20% interest.

Default on the first payment then renegotiate is the easiest. Work with unlicensed vendors(tribal or foreign). Not state. They have no teeth with claims because they aren’t obeying the state laws so collecting is hard for tribes if not impossible.

Q: What percentage of your customers are one time (or at least, super rarely) customers compared to the every week sort of customer?

Payday Lender: About half are habitual repeaters.

Q: That’s actually far better than I feared, but still far too many people trapped in that cycle. Any insight into why? Do the people lack skills? Does your area lack jobs? Is there some common theme, like medical bills or bail money that’s very common?

Payday Lender:  It’s lower than the industry average because my business model doesn’t actively pursue reloans. We can’t take more than 2 loans out on a person per year. I have seen everything from my car broke down and I just need this to get me to work; to, repeat offenders who make $80K a year (verified). I really don’t know of commonality I think there’s just a wide range of reasons.

I do have an idea how to fix it. Force contracts to carry an amortization schedule with a minimum number of payments. Say, 10 equal payments for example. Each payment reduces principal (NO INTEREST ONLY). This prevents them from HAVING to take a loan out every two weeks to cover bills. Don’t allow more than 2 loans per household per year, industry wide not just per lender. They will jump from lender to lender otherwise. This should be used as emergency money not a check cashing service.

Look, I make enough money following the rules and playing nice I don’t have to ream them too.

Q: Why is money the most important thing to you?

Payday Lender: Its not but its close. Money means freedom: freedom to live how I want.

Q: And you feel it’s acceptable to use others to get what you want, even if that means that their quality of life is diminished?

Payday Lender: I also feel like this is insulting to my customers. Shit happens and if it happens to someone with awful credit what are they supposed to do? So yeah I profit from that. Does it bother me? no.

I don’t advertise, my customers come to me, no ones forcing them to take a loan. And unlike other paydays I amoritize rather than taking the full amount and forcing them to renew. Instead of 1 huge payment at the end of the pay cycle forcing them to take a new loan. I take small payments for several weeks so if its truly just a bad luck thing. They arent locked into a never ending cycle.

So no I have no qualms about what I do or how I do it.

Whats the alternative? No one comes to me thinking its a wise life decision.

Q:I’ll just be leaving this here… Youtube

I’d like to hear OP’s take on John Oliver’s report (see above link) on pay day loans. Do you think it is accurate?

You sound like a rare breed indeed. Kudos for not trying to milk every dime out of ppl that you could.

Payday Lender: I love John Oliver. I have HBO and watch every episode. This episode made me think a bit about everything else I see though. He paints with such broad strokes it misses the nuance, like the show News Room, I think that nuance is truly where the difference lay.

The interest rates suck, but that’s not the issue. They have to because of the default rate is so high.

If I knew I was going to get my money back I could charge 20% like a credit card. But 25% of the time we lose not just the principal but the entire cost of servicing the loan ( to contrast bank loans have less than a 0.25% default rate). So, that means that the other 75% of payers have to make up that massive loss.

Lend someone 1000 dollars and it costs you 100 to service, so you are out $1100. You have to make $1200 to really make it worth it. So if you lose $1100, 25% of the time, how much do you need to make on the other 75% of the time just to break even. How much is that in interest to the other loans? Do the math…it sucks. And yes 25% is the industry average default on first time payments [FTPD] NOT the total default, that’s even higher.

I do think there’s severe problems with the industry, and that predatory renewals needs to be addressed (see my other comments above). The interest rates aren’t really the problem though… 500% is calculated on 2 weeks drawn out for 52 (so its really 20 to 25% a payment). If you can find me someone who can collect for 52 weeks I will show you the next Bill Gates; it just doesn’t happen.

So here’s the fix. Set a max to 200% APR, then force it carry it for 10 payments and no more than 2 loans a year, that way they have the opportunity to get out of debt, and you can still make some money.

I also think that this is a necessary service. Our customers don’t want to go bankrupt. They want to pay their debts, but that intention doesn’t matter to banks or lenders, so they can’t get a loan anywhere else. I have actually had customers in tears thanking me because they have no other options. The problem is there’s really no regulations on the industry. I can setup with a tribe and basically write my own law. So, some of my compatriots use that so they don’t have to obey state laws; this means they can do dumbass shit like auto fund renewed loans based on some bs contract no one read.

So I have limits, I draw the line, I know the difference between really fucking someone, and just covering my risk.

I am open to alternatives too. If not this what do we have, loan sharks?

Look, you don’t pay me I send you an angry letter; not break your legs.

Here’s a challenge. Tell me a better model. Vet it with financials. I wanna see spread sheets, planning, a well thought out idea. You tell me that and I will not only fund it, implement it with my call centers, staff, but I will even pay for the lobbyist. Hell, if its good enough I would hire you and get you a share of the profits.

Q: So whats the alternative? Illegal loan sharking?

Payday Lender: If you push it out then the loan sharks will come back. Remember prior to the 90s how the mob was pretty powerful in places like Vegas Chicago NY KC Boston(pretty much every major city)? Now they aren’t…

I am all for fixing the regs getting rid of tribal/foreign and repeat loans. Say a cooling off period before they can re-lend.

But It also used to be that you knew your banker. And if you needed $500 to fix your truck to get to work you would walk in and say “Hey Bob I need 500 can I pay you back over the next few months?” The regulatory environment and consolidation of banks broke that. So now where are you to go?

And don’t get me wrong the big banks needed those regs I am all for it.

I’ve seen it multiple times, and again its a very narrow view, and the problem is then everyone’s assumptions are based on that kind of narrow view. For example, who said I have a location? I used to, but stores are like a big “Rob Me” sign, I am online only now, and lend to residents in the state of Nevada and California where I am licensed to operate by the state. You have to go looking to find me, I don’t advertise.

Unlike the guys Oliver is talking about which makes it seem like everyone operates that way.

Here’s the difference between state and tribal.

Because of that state license, I have to follow lending rules in that state, like maximum interest rates, no more than 2 loans per person per year etc. I get audited every quarter to make sure I am doing this correctly (by both states). I pay taxes. I have to keep a bond with the state to make sure if I break these rules I can refund my customers. I can’t auto re-loan. I have to follow state collection guidelines. It goes on.

But on the flip side, I have protections which allow me to file actions against those who don’t repay me.

Tribal/Foreign based lenders don’t have to do any of this. They pay a fee to a tribe then write their own rules. And Oliver is talking about us as if its the whole industry when in reality its about half.

Q: This should be the most visible comment. it explains everything I was wanting to know about this from your side of it. Maybe I am missing something that makes you out to be a horrible person with a horrible industry (which I had previously believed) but you are running a business

Payday Lender: Thank you, I am sending this thread to the friend who put me up to this. She thought I was really going to get reamed. (which in fairness some have but nothing too harsh)

Q: Shit man, people are giving you hell and the credit card companies are cool? You’re filling a void in the marketplace.

Payday Lender: Honestly no ones giving me too hard of a time. It’s all been super civil. I thought it would be a lot worse.

But we wont let you dig too deep of a hole… I want my money back.

So here’s the math on the credit card. $1200 charged. 3% minimum payment and 20% interest is $2310 in Total payments back.

Borrow 1200 from me and run it to term its $2800 So that’s 20% higher than a credit card. But if your credit was good enough to get a card, you wouldn’t be coming to me, so yeah I have to charge more.

Q: How much money would a person need to start a business like this? How does one get into this business?

What happens to a market that is not allowing new talent in to proliferate the business?

Payday Lender: No one said that. I said its hard. The biggest lender in the industry is about to go out of business so there’s about 1 billion up for grabs… go get it if you want it.

Q: What do you mean by this? Do you mean take out s big loan and just not pay it back because they won’t be able to collect?

Payday Lender: No I mean theres about to be a lot of room for upstarts in the industry.

But shit now that you mention that… google biggest payday lender, borrow from him, then don’t pay him back …hes tribal and unlicensed. So unless you live in a few super red states he can’t collect or submit you to a credit agency. Only borrow online. Not in a store front. Stores are licensed.

Q: Could he collect or submit to a credit angency in Mississippi?

Also. Is there anything he could do to get the money back that would have bad effects for me? Could he sue me? Is he likely to do so? Is this a common scam to pull? What am I looking at by doing this? Sorry for all the questions. I only ask because I’m in a really tight spot. And desperately need about 1600 dollars.

Payday Lender: Collections is just annoying calls and you can send a cease and desist.

The credit reporting would have be in the contract, but if its a tribal lender I doubt they do. If its tribal they are breaking state laws, so they cant go to the states attorney to file an action or lien. It also means they really can’t sue either.

If they are a state Licensed Lender in Mississippi then their website or store location would have a copy of the License on their website. If they are state licensed, then they can sue and file actions.

If its a store front its probably state licensed. Online is about 70/30 where 70 are tribal.

If you are interested in the sector look into micro financing for developing nations as well. Cheaper easier, no regs, and a lot of free flowing money from investors.

Q: Would you mind going a little bit more in depth on this? What is micro financing for developing nations?

Micro financing is a kinda cool new idea. Developing countries have no real banking or credit sector. They also have lots of entrapeneurs. The dollar goes a long way there and they dont need much.

500 or so to start a business. So you get 10 to 20 of them together. Each get 500 to 1000 and they share risk with each other. Theres already people in those countries looking for lenders and act as middle men… so lend to the businesses all at a reasonable rate for a high risk investment 20 to 40% since theres a shared risk theres a high liklihood of repayment. And its not your money its investors who can afford the loss. If you are really slick, you set it up as a charity so if the investors lose money its a tax write off so who cares?

Rinse and repeat.

From Jer: You want to know more about “micro-lending?” Start here with “Confessions of an Economic Hit Man” by John Perkins and “Banking to the Poor” by Muhammad Yunus


Q: I’ve seen you haven’t received a lot of support here. For what it’s worth I know you fill a valuable space. People need money they don’t currently have and you provide that to them at a rate that is proportional to the risk the customer represents. Let’s be honest if they qualified for a credit card or any other option, they would use that first. I’d rather have people owe a local business man a few grand rather than owe the mob a few grand. Thanks for doing this AMA, very interesting.

How old are you?

How long have you been doing this?

How much money did you start with?

Did you take out a loan to start?

How comfortable are you living right now?

Payday Lender:

3 years ( I was a loan officer at a bank).

I had $100K of my own and another 1.5 million from investors

No, you can’t get a business loan large enough for a start up SBA just won’t allow it.

I make over 2 million a year and employ 23 people all of whom make over 40k a year + bonuses and benefits.

Q: What’s your professional background? Did you work in other financial service jobs/institutions before you opened your own shop?

Payday Lender: Banking was my background. I was a loan officer out of college.

Finis!

So Dear Reader, what do YOU think? Shoot an email to me!!

Do you want to get started in “The Business of Lending Money to the Masses?” Click here: I WantMore Info.

How to Start a Consumer Loan Business: Installment lending, car title loan lending, payday loan lending, personal loan business

Click This Image for Some Light Reading 🙂 Over Your Weekend!


*************************************
Note to my Reader: This originally appeared here: Thread
And no, it is not me. Apollonius01, if you’re reading this, WE WOULD LOVE TO HEAR FROM YOU! WELL DONE, BROTHER! Jer
************************************

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10
Aug

HB 123 Ohio Small Dollar Loan Law

Ohio Payday Loan and Credit Services organization Bill 123 as passed: The bill will require lenders offering certain types of consumer loans and regulated under the Small Loan, General Loan, or Credit Service Organization laws to obtain licensure instead under the Short-Term Loan Law.

Overview
In FY 2018, the Consumer Finance Section of the Division of Financial Institutions within the Department of Commerce (COM) oversaw approximately 1,600 licenses and registrations under the various lender laws covered by the bill. Overall, the changes in the bill will steer lenders who currently offer small-dollar, shorter term loans and wish to continue to do so in the future from licensure under the Small Loan, General Loan, or Credit Services Organization laws instead to licensure under the Short-Term Loan Law.

The modifications to the Short-Term Loan Law in the bill include (1) increasing the maximum loan amount from $500 under current law to $1,000 under the bill, (2) increasing the duration of loans from at least 31 days to a maximum duration of one year, (3) establishing a monthly maintenance fee that is the lesser of 10% of the originally contracted loan amount or $30, and (4) establishing requirements for a borrower’s eligibility for a loan that has a duration less than 91 days. The bill also caps the total amount of fees and charges that can be charged to 60% of the  originally contracted loan amount.

To differentiate between the loans that can be made under the Short-Term Loan Law, the bill requires that loans made under the Small Loan Law and General Loan Law have either a minimum duration of more than one year or a loan amount greater than $1,000. Additionally, the bill prohibits credit services organizations (loan brokering services) from brokering extensions of credit when the amount is less than $5,000 and the repayment term is under one year.

Consumer finance licenses and registrations

The bill will require payday lenders to… here’s the actual Bill 123 as passed and signed by the Ohio Governor:

[pdf-embedder url=”https://paydayloanindustryblog.com/wp-content/uploads/2018/08/HB-123-Passed-Effective-October-2018.pdf” title=”HB 123 Passed – Effective October 2018″]

How to Start a Consumer Loan Business: Installment lending, car title loan lending, payday loan lending, personal loan business

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09
Aug

The Business of Lending Money to the Masses: What’s Going On?

Want to know what’s REALLY going on in “The Business of Lending Money to the Masses?”

Installment loans, payday [single payment] loans, car title loans, personal loans, cash advances… call them what you like, here’s a free method you can use to find out exactly what’s happening in our industry without having to deal with the BS a vendor might feed you.

JUST ASK!

Yeah! Just walk into a local payday loan, car title, pawn shop,check casher, gold buyer store or whatever and ask the employee, “How’s business?”

Yep, it’s really that simple!

You maybe surprised at how candid these clerks and owners can be.

You can portray yourself as a customer or as a fellow business owner depending on the situation as you enter the location.

If it’s really busy in the store, just lurk! Watch! Listen! Learn!

When appropriate, approach an employee and ask open-ended questions:

~ How’s business?
~ Would you like to own a business like this? If yes, why? If not, why not?
~ What’s your biggest problem right now?
~ What’s your greatest opportunity?
~ How did you get started in the business of lending money?

Learn to ask a few questions and then just LISTEN!

Don’t interrupt or butt-in.

You’re not there to display your knowledge and virtues.

You’re there to learn; to gain insight.

What loan products and services are being offered? Anything you should add to your arsenal?

What’s the condition of the location? Is it clean and orderly?

What about signage and lighting? Any ideas YOU should implement in your lending business?

Is it what we refer to as a “No” store?

You know what I mean! Signs plastered all over the place saying”No” this and “No” that. As if management is LOOKING for any excuse NOT to do business with their customers.

Don’t forget to make it a goal to insist that not only you, but your entire team perform this task regularly and consistently.

Pay your employees to visit your competition on their turf AND and call Online money lenders for information gathering as well.

After your employees perform these “reconnaissance missions,” take them to Starbucks, sit down with them, and review their experience!

Probe. As you discuss their findings and observations, train them to get better at this in the future. Alert them TO THE FACT that this research will be a continuing part of their job in the future.

We insist each of our employees perform this task once each month. We systematically map out our competitors and schedule our employees to visit a different competitor’s location and to call the dominant Online lenders in our geo area.

It’s not uncommon for us to pay the fees for a $100 loan for our employee at a competitor. We reimburse our employee, pay for their time and make copies of all the loan documents, pamphlets, brochures, flyers, etc. that they’re given.

So… get the idea? If you want to know what’s going on in your market, JUST ASK! GET OUT THERE!

And if you’re not yet in a niche you’ve been thinking about entering, VISIT those locations that are already in the space you’re interested in. Take cash for gold buying for example. You want to learn about this niche? Hit the road! Visit 10 stores today, ask a few open-ended questions, then SHUT-UP and LISTEN!

What do you think? Let me know: Jer Trihouse

“The Business of Lending Money to the Masses!”
Installment, payday, car title, cash advances, personal loans & line-of-credit lending EXPLAINED.
Make Money by Lending Money
http://www.ScrapGoldGuru.com

Jer Trihouse 702-208-6736 Cell
Knowledge Store: Tribe & State-by-State Licensing Models

How to Start a Consumer Loan Business: Installment lending, car title loan lending, payday loan lending, personal loan business

Click This Image for Some Light Reading 🙂 Over Your Weekend!

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