Tag: cfpb

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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11
Oct

CFPB Takes Broadside- Leadership Structure Ruled Unconstitutional!

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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09
Jul

5000 Payday Lenders Win via U.S. House of Representatives

Payday Loan Lending

By Jer Trihouse. The battle between the CFPB and payday lenders is not yet decided. It appears the members of the  U.S. House of Representatives understand how important access to credit is for consumers throughout America!

It’s refreshing to witness the heroic efforts by our representatives in the House against unelected CFPB bureaucrats and their draconian efforts to place  credit restrictions on consumers for solving their daily financial challenges.

Car title loan company

Start a PDL Business

FISCA represents the thousands of small mom and pop payday loan operators offering short-term, small dollar loans to their  clients.

Having actually visited payday loan stores in California, Nevada and Tennessee recently (unlike any CFPB employee), I can attest to the fact that consumers are scared. They are VERY worried that they will no longer have access to a $300 – $1000 payday loan from thier local loan center when facing a financial emergency.

Payday Lenders Win

Per Ed D’Alessio, FiSCA’s Executive Director, “By passing H.R. 5485 and rejecting the Sewell-Waters Amendment, this bipartisan group of lawmakers took an important step in keeping critical and often lifesaving lines of credit open for hard-working Americans.”

“H.R. 5485 requires the Consumer Financial Protection Bureau (CFPB) to pause the implementation of the proposed federal rules governing small dollar lending in America, an extensive and economically devastating regulation that would deny access to short-term credit options to millions of Americans.”

Financial Service Centers Of America Statement In Response To H.R. 5485 And Sewell-Waters Amendment Votes

WASHINGTON, July 8, 2016 /PRNewswire/ — Financial Service Centers of America (FiSCA), the national trade association representing 5,000-member financial service center locations around the U.S., issued the following statement today in response to the votes on H.R. 5485, the FY 2017 Financial Services and General Government Appropriations Act, and the Sewell-Waters Amendment #17: “We applaud the…Continue Reading..

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