Tag: cfpb

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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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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21
Nov

CFPB-Unsecured Loan Industry to Prosper Under New CFPB Head

CFPB

This originally appeared on Mortgage News Daily-by BY: ROB CHRISMAN  here: Here’s something to think about. If the CFPB “dials things back,” wouldn’t the states step in and increase their consumer-focused regulatory levels? Multi-state lenders certainly wouldn’t like that. Since the state regulators have been in regular communication with the CFPB and knowledgeable as to the Bureau’s regulations and impact upon consumers (the protection of whom the states have always viewed as their primary function) it can be expected that we will see more state regulation as the CFPB’s role is reduced. In Pennsylvania, for example, a recent bill supported by the Department of Banking and Securities to license mortgage servicers, incorporated the CFPB servicing regulations. This is a trend that may become viable for other states regarding those CFPB regulations that might be eliminated or reduced in effect.  This is, of course, speculative at this point but it should be considered as we move ahead representing the industry in the states.

Payday Loan ConsultantsAccording to media sources, President Trump is expected to select Mick Mulvaney, the current Director of the White House Office of Management and Budget (OMB), to serve as the interim Director of the CFPB upon Richard Cordray’s resignation at the end of this month. The CFPB is not going away, and neither is Dodd-Frank, although policies and procedures may change. And do we really want it to, given that lenders and vendors in the industry spent billions of dollars implementing the Dodd-Frank framework in our businesses.

Mulvaney is a former South Carolina congressman and served on the Financial Services Committee. Mulvaney had previously been quoted during interviews as being dissatisfied with the CFPB’s performance and even said its lack of accountability showed it to be a “joke”. He was one of those in Congress who reportedly wanted the CFPB to be eliminated. Certainly, the administration intends to reduce federal regulations and the CFPB would make a prime target.

Julian Hebron of The Basis Point issued his thoughts on the future structure of the CFPB.

Ever heard of Think Finance? It doesn’t matter – the CFPB has. On November 15, the CFPB announced it had filed a complaint against Think, a Texas-based service provider, alleging that it had assisted in the collection of loans that were, in whole or in part, void under state law. The complaint filed in the U.S. District Court for the District of Montana alleges that the service provider, which provided services to three tribal lending entities engaged in the business of extending online installment loans and lines of credit, along with two companies responsible for the collection process (collectively defendants), assisted in the collection of loans that consumers were not legally obligated to pay based on identified states’ usury laws or licensing requirements.

Rob Chrisman began his career in mortgage banking – primarily capital markets – 27 years ago in 1985 with First California Mortgage, assisting in Secondary Marketing until 1988, when he joined Tuttle & Co., a leading mortgage pipeline risk management firm. He was an account manager and partner at Tuttle & Co. until 1996, when he moved to Scotland with his family for 9 months.
He returned to the United States in mid-1997 and ran Secondary for Standard Financial, a sub-prime lender in northern California. In late 1997 Rob was hired by CrossLand Mortgage to start, and be the president of, a sub-prime company named OnCall Mortgage (a division of CrossLand). OnCall Mortgage was in existence until Wells Fargo purchased First Security Bank (the owner of CrossLand) at the end of 2000.
Rob then joined CMG Mortgage, a wholesale mortgage bank, as the Director of Secondary Marketing. In early 2003 and re-joined Tuttle Risk Management Services, Inc. TRMS (now Compass) provides mortgage pipeline risk management for mortgage companies and thrifts that seek to originate and sell loans into the secondary mortgage market. In November of 2006 Rob left TRMS to become the Director of Capital Markets for RPM Mortgage, a retail residential lender, leaving there in late 2008 to focus on not only publishing a widely read daily market commentary on current mortgage events but also on his family.
He is on the board of directors of Peoples Bank, a mid-sized depository in Kansas, and of IFC, a financial services company which advances capital to heirs, He is also an associate of the STRATMOR Group, a member of the California Mortgage Bankers Association, and of the Mortgage Bankers Association of the Carolinas and its membership committee. Rob has provided expert witness services for mortgage and real estate-related cases, has lectured to groups around the country.
Rob holds a BS from Cal Poly, San Luis Obispo, and an MBA from UC Berkeley.
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08
May

Fewer Companies Settle with CFPB

The Business of Lending is the Oldest Pofession.

The Wall Street Journal [which I have appeared in on several occassions] ran an interesting piece on the CFPB. The fact is, fewer companies are willing to settle with the CFPB today. This is huge. 

Fewer lenders willing to settle with CFPB = more investors/capital scrambling to enter the B2C and B2B alternative lending space. In spite of the competition from the balance sheet and off-balance sheet lenders, my phone is ringing. On the other end of the call? Entrepreneurs, capital groups, technologists… contemplating entrance into the business of lending. Lenders find it hard to ignore the 30%+ net returns available. The banks simply cannot service the demand for small dollar loans. Lenders continue to salivate due to the low cost of money coupled with ease of entry, mobile technology, tribe sovereignty, a more stable and defined state regulatory environment…

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