THE BLOG

08
Nov

Great News: CFPB Payday Loan Lending Rule Stayed! Opportunities Abundant

Consumers WIN BIG! CFPB payday loan rule shut down!! And DEALS/OPPORTUNITIES are immense today.

Frankly, there has never been a better time to be “lending money to the masses.”

  • Demand for credit by borrowers is huge.
  • Stats are all over the map – depending on the source – but something like 60% of US households do not have access to $1000 cash in an emergency.
  • The big sub-prime lending season is almost upon us.
  • Jobs and ability to pay us back are through the roof.
  • Consumer optimism is sky high.
  • Washington D.C is not likely to devise too many roadblocks that could stifle all this enthusiasm.

THE BIG NEWS TODAY?

U.S. District Judge Lee Yeakel reversed a previous order and granted, in part, the request by acting CFPB Director Mick Mulvaney and two payday loan industry trade groups to delay the payday loan rule’s August 2019 compliance date. “We sought a delay in order to help consumers in general, and borrowers specifically, enable lenders to continue to solve sub-prime borrowers access to credit throughout the USA and  from having to comply with an old CFPB rule before their revisions were even finalized!

The district court in Texas issued an order staying the August 2019 compliance date of the payday rule pending further order of the court.  The court reasoned that, in light of the CFPB’s representation that it would engage in rule making to reconsider both the rule and its compliance date, lenders and consumers facing financial hardships would suffer irreparable harm if the existing compliance date were not stayed. 

Judge Lee Yeakel left the stay of litigation in place, and ordered that the parties file a joint status report.

Meanwhile, know that opportunities in the “business of lending to the masses” today are unfathomable.

I RECEIVE CALLS EVERY DAY! Capital is a commodity. Lacking experienced lending expertise/talent, money not put to “work” is useless. Mid-20’s ROI to “back seat” investors are available. Texas 3rd party lender 12%+ secured returns are out there. Seasoned Fintech lenders having 5+ years lending experience with proprietary loan management software and  apps are on the hunt – now – for capital to “put on the street.” Instant 24/7 loan funding is now available. Virtual, instant debit/credit cards are here. New LMS companies are on the prowl to deliver state-of-the-art solutions for borrowers and lenders. Stores are for sale…

You have a deal? You need a deal? Email your contact info and a bit of “color” to: TrihouseConsulting@gmail.com

OR, wander on over to our offerings to “learn the ropes:” Learning Center

Vendors go here and get listed: Vendor Resources

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31
Oct

The CFPB- Like Giving Whiskey & Car Keys to Teenagers – More Good News for Lenders

Giving money and power to government is like giving whiskey and car keys to teenage boys. [P.J. O’Rourke.]

It’s a fact that things are looking really good for those of us who make it our “business to lend money to the masses!”

Yeah, it’s competitive out there! Yep, there is a lot of fraud. FTD [first time defaults] are scaling up.

CAC ‘s are on the increase. Elevate revealed a funded loan costs them $225 each. Enova is close. On the other hand, we have portfolios with <$80 CAC’s and <12% FTPD’s.

The economy is blazing along, average folks feel good about their prospects, they have jobs and they’re not hesitant to spend their money on new phones, Netflix, prepared food delivered to their homes while they kick back and watch Game of Thrones…

And we have Judge Kavanaugh & the CFPB  🙂

Judge Kavanaugh DOES NOT LIKE THE CFPB. Isn’t that a pity – I write facetiously.  

This is an excerpt from Housing Wire by Ben Lane [link below]:

“One issue that Kavanaugh is clear on is the Consumer Financial Protection Bureau.

“Kavanaugh believes the CFPB, as it is currently structured, is unconstitutional.”

“In 2016, Kavanaugh authored the Court of Appeals decision that declared the CFPB unconstitutional due to its leadership structure. The case that led to the CFPB being declared unconstitutional, which was brought by PHH, dealt with how much power the agency’s director held.

“The CFPB is the “single most powerful official in the entire U.S. Government, other than the President,” in terms of unilateral power.

“As an independent agency with just a single Director, the CFPB represents a sharp break from historical practice, lacks the critical internal check on arbitrary decision making, and poses a far greater threat to individual liberty than does a multi-member independent agency,” Kavanaugh wrote in his decision. “All of that raises grave constitutional doubts about the CFPB’s single-Director structure.”

“… but with Kavanaugh in tow, could other challenges to the CFPB be coming? They already are.”

Back in June, U.S. District Judge Loretta Preska of the New York Southern District declared the CFPB to be unconstitutionally structured for different reasons.

“Could that case end up working its way all the way up to the Supreme Court? It’s certainly possible, considering that Preska’s decision goes directly against a decision of a higher court.”

“… Justice Kavanaugh will likely vote to kneecap the bureau (or worse).”

“That sound you hear? That’s the death clock on the CFPB moving a little bit closer to midnight.”

Here’s a link to the Original Piece at Housing Wire: LINK

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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19
Jan

CFPB Drops Suit against 4 Payday Loan Tribes

The CFPB continues to capitulate in the payday loan space!

President Trump and acting director Mick Mulvaney have had an astoundingly positive influence on the outlook for payday lending and the upbeat environment for US households as well.

Previously, the CFPB received an astounding 1,000,000,000+ comments from US consumers “praying” for continued access to payday loans and other small dollar loan products.

These consumer comments in the form of electronic and hand written communications fell on deaf ears at the CFPB.

The CFPB ignored them. Additionally, the CFPB ignored the payday loan industry, their employees, vendors and pro-payday loan legislators throughout the USA – of whom there are many.

This continued attack of a lawful industry became further weakened today by the announcement that the CFPB is dropping all lawsuits against 4 payday loan tribal lenders!

The lenders are: GOLDEN VALLEY LENDING, INC., SILVER CLOUD FINANCIAL, INC., MOUNTAIN SUMMIT FINANCIAL, INC., AND MAJESTIC LAKE FINANCIAL, INC.

The reason the CFPB threw in the towel? They want to ” consult with new leadership” at the CFPB  🙂

Before Hon. Julie A. Robinson, the FED’s filed a “Notice of Voluntary Dismissal” against the four lenders owned and operated by the Habematolel Pomo of Upper Lake.

NO REASONS WERE GIVEN!

[Sponsor: Need a bank account for your MSB or lending business? Want to “push” loan funds to a consumer’s phone? Need ACH, credit card or debit card process? Need a second “backup” enabling your Team to sleep at night? Get an introduction here: Click “PROCESSING.”

Recall that last October, under the lead of former Director Richard Cordray, the CFPB had intended to implement new rules requiring all lenders to make a determination as to the borrower’s ability to repay the loan.

This would have caused massive disruption; after all, the typical payday loan is less than $400! How on earth coild a lender be expected to analyize ther loan applicant’s personal income, household and expense situation? Most of these folks are simply caught in a temporary financial emergency; utilities turned off, car repair, prescription needed…

For many LONG months, the payday and car title loan industry has been expecting overly aggressive CFPB rules to be implemented.

Today? These expectations are at an end! President Trump’s administration has delivered a HUGE dose of common sense to “the business of lending money to the masses.”

[As a result, our inbound phone calls and emails for consulting, capital raises, bank accounts, credit and debit card processing and “$$ push to borrowers” is escalating dramatically! TrihouseConsulting@gmail.com]

These are proving to be VERY GOOD TIMES for US households and lenders! It’s been such a LONG time that we’ve had a sense of optimism and entrepreneurship in America.

FEELS GREAT!!

Here’s the announcement from the CFPB regarding the 4 tribes:

notice-of-voluntary-dismissal-c-4-Tribes-01-19-2018

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14
Dec

CFPB Employee Files Whistle Blower Charges: Payday Lender Ace Cash Express $10M Fine Bogus

A former CFPB examiner filed whistle blower charges against her employer, the CFPB, claiming she was terminated for refusing to falsify ACE Cash Express documents that resulted in a $10,000,000 fine levied against Ace!

The CFPB continues to be revealed as a reprehensible, rogue government organization whose management enabled their personal prejudices to attempt to destroy lawful, private and publicly traded businesses.

Cassandra Jackson, a former CFPB employee, filed documents strongly indicating she was fired for attempting to report that Ace Cash Express was adhering to CFPB rules and regulations.

It’s common knowledge that Ace Cash Express chose to pay the $10M fine rather than enter into costly, lengthy legal challenges against the one governmental agency having unfathomable deep pockets.

Ms. Jackson also asserts that she “encountered widespread racism and gender discrimination from management” and was eventually forced out due to an “incredibly hostile work environment.”

Jackson said her superiors at the CFPB insisted she falsify documents while she investigated Texas-based payday lender, Ace Cash Express.

Jackson said “she was asked to remove document evidence proving that Ace Cash Express adhered to CFPB regulations and her superiors insisted she write a report including findings she knew to be “false and fabricated.”

“I was specifically told to cite Ace Cash Express for a violation for which I had verified the company was in compliance and to state that Ace Cash Express did not provide, and that the CFPB did not receive, documents that would have satisfied the CFPB’s guidelines, despite having received that information from Ace Cash Express,” Jackson said.

Cassandra Jackson, a former CFPB employee, filed documents strongly indicating she was fired for attempting to report that Ace Cash Express was adhering to CFPB rules and regulations.

Cassandra Jackson, a former CFPB employee, filed documents strongly indicating she was fired for attempting to report that Ace Cash Express was adhering to CFPB rules and regulations.

 

CFPB Employee Files Whistle Blower Charges: Payday Lender Ace Cash Express $10M Fine Bogus

CFPB Employee Files Whistle Blower Charges: Payday Lender Ace Cash Express $10M Fine Bogus

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30
Nov

CFPB Elephant Dies-The PDL Industry is Dancing in the Streets WITH Their Customers

By Jer– New Sheriff at CFPB: The PDL Industry is Dancing in the Streets WITH their Customers!

As pointed out on several industry media sources, “There is a new sheriff in town at the CFPB!” 
Euphoria is overtaking the private, Tribe and publicly owned payday loan, small dollar loan, unsecured loan, car title lending… industry.
It’s as if an elephant has been sitting on our chests since August of 2013 and finely wandered off TO DIE!
CFPB

CFPB

You know the old story about the matriarchs of the elephant families leaving the herd to wonder off to their elephant graveyard?

Well, now we can add a similar story to the bunglers, meddlers, hypocrites and unelected, ivory enshrined bureaucrats who  pontificated from their lofty perches about what THEY think is good for consumers in America.
All of us took a hit by CFPB government employees. Firearms dealers, payday lenders, car dealers, ammo dealers, shooting ranges, gaming, marketing companies… hell, even strippers!
World Acceptance, Santander, PHH, Enova, EZcorp, Avant… are all shrugging off any future unwarranted attacks against them by the CFPB while worried consumers of these small dollar loan products are relieved by the obvious continued access they’ll have to short-term loans for solving their financial worries.
YEP! We live in wonderful times!! Eventually, persistence pays off! For ALL of us.
And, on the heels of the latest CFPB defeats, new lenders continue to launch via both State and Tribal collaborations, industry veterans continue to participate in capital raises, the “big boys” in our space expand, and the biggest seasonal demand by consumers is about to begin!
Curo Group: Raising $100M with the sale of 6.7M shares at hoped-for range of $14-$16 each.

Entreprenurs with serious experience in the unsecured lending space going “balls to the wall” with teams of tech and finance at their helm.

Over the last five sessions a group of payday lenders and other former or potential CFPB targets have been partying: World Acceptance Avant, Lendup, Lending Club, Dave, WRLD, OneMain Holdings, Santander Consumer, PHH Corp. Enova, Ezcorp and on and on!

Let the GOOD TIMES ROLL!!!!!

Need help making money by lending money to the masses? Start Here!

That’s all folks: TrihouseConsulting@gmail.com

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