Your Number One Challenge in Small Dollar loan Space?

What’s your #1 challenge in the small dollar loan space today? Take 30 seconds to tell me and I’ll share the results of our 10K+ readers.

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Whoop dee do: Cash America Fined $5M Plus Reimbursements

Whoop de doo!  Wow! $5M in fines and $14M in “payback.” Cash America (CSH) had $46M in net INCOME for the 3rd quarter 2013. This will devastate them. Buy CSH; go long… This is OLD NEWS! CSH discussed their Ohio issues as early as last December. They already began issuing “reimbursements.” So their stock takes a big hit! Only the “little” guys failed to see this coming. Enova, their ecommerce platform is “killing it.”

Guys, if the media is reporting it today, you know this is of little consequence and already factored into the stock price.

Read The Washington Post article article anyway.



FDIC Issues Final Guidance Regarding PDL Deposit Advance Products

Press Release

FDIC Issues Final Guidance Regarding Deposit Advance Products

November 21, 2013
Media Contact:
Greg Hernandez (202) 898-6984
Cell: (202) 340-4922


The Federal Deposit Insurance Corporation (FDIC) today issued final supervisory guidance to FDIC-supervised financial institutions that offer or may consider offering deposit advance products. The guidance is intended to ensure that banks are aware of the credit, reputational, operational and compliance risks associated with deposit advance products and have taken steps to mitigate these risks effectively. This guidance supplements the FDIC’s existing guidance on payday loans and subprime lending, as well as the FDIC’s guidelines on small dollar loans.

Jer-Ayler-Trihouse-ConsultingJer Ayler at Trihouse: FDIC Chairman Martin J. Gruenberg said, “The final supervisory guidance released today aims to alert financial institutions to the risks posed by certain deposit advance products and to encourage institutions to meet the demand for small-dollar loans through affordable products that are prudently underwritten and designed.”

Deposit advance products are a type of small-dollar, short-term credit product that some depository institutions offer to customers maintaining a deposit account, reloadable prepaid card, or similar deposit-related vehicle. The customer takes out a loan, which is to be repaid from the proceeds of their next direct deposit. Deposit advance products share a number of characteristics seen in traditional payday loans, including high fees; short, lump-sum repayment terms; and inadequate attention to the consumer’s ability to repay. As such, banks need to be aware that deposit advance products can pose a variety of credit, reputational, operational, compliance and other risks.

The FDIC recognizes the demand for responsible small-dollar credit products for consumers that are underwritten with attention to the customer’s ability to repay the loan without needing to borrow repeatedly to meet necessary expenses. The FDIC’s 2007 Affordable Small-Dollar Loan Guidelines encourage insured institutions to offer small-dollar loan products that have affordable, reasonable interest rates with no or low fees and payments that reduce the principal balance of the loan. If structured properly, small-dollar loans can provide a safe and affordable means for borrowers to transition away from reliance on high-cost debt products. A number of banks are currently offering such small-dollar loans to their customers. The FDIC encourages banks to continue to offer these products, consistent with safety and soundness and other supervisory considerations. The FDIC also encourages banks to develop new or innovative programs to effectively meet the need for small-dollar credit.

Final Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products – PDF (PDF Help)


Job: Collections Manager Position

Collection Manager – Manage Loan Operations and Loan Customer Care

This is a management level position held accountable for the booking of all loans and the subsequent customer servicing whether initiated by customer inquiry, company policy, customer delinquency, or centralized outbound marketing. This position also manages the recovery of property pledged by customers to the company and other recovery of loss assets by legal, collection agency, asset sales or other methods.

NOTE: Candidate must be willing to relocate to a South East State


  • Organize a program of customer loan servicing beginning with the loan booking process through the repayment and thank you process.
    • Organize a customer contact effort to occur on loan date plus one to thank the customer, recertify the loan terms and responsibilities, recertify the customer contact information and set expectations of client behavior.
    • Organize a system of customer contact pre- payment due dates to encourage payment on date due and at most date due + 3 days.
    • Organize a systematic outbound contact program to former customers and selected target customers to enhance loan sales online and at the stores.
    • Determine the appropriate technology to support the loan servicing operations and management reporting beginning with understanding the Cashwise systems currently in use by the company.
    • Determine the voice, text, email and other mediums most likely to reach the customers and organize the company efforts to use these mediums.
    • Determine the staffing needed to meet the customer loan servicing objectives and select, train and manage this staff for cost effective results.
    • Organize a system of collections designed to preserve the customer relationship that begins day due and continues during the 60 days from due date to charge off.
      • Maintains collection guidelines in written form in a policy and procedures manual that is easily updated and the basis for training of staff.
      • Manage the collections staff to increase revenue and maintain customer relationships
      • Select, train, and manage the collections staff to hold company losses to management selected targets.
      • Coach the collections staff on applicable laws and regulations (State and Federal) and ensure complete legal compliance.
      • Determine with management proper incentive compensation for the collections staff.
      • Organize a system of asset recovery for assets pledged to the company including policies for the use of outside recovery contractors and the monitoring of their actions.
        • Coordinate the charge off of assets deemed uncollectible within the company 60 days from due date policy.
        • Plan the recovery of all assets charged off including policies for the use of outside collectors, attorney’s, debt sales etc.
        • Organize the company response to all bankruptcy filings by customers.
        • Participate in the setting of loan underwriting standards based on trends in the loan servicing and collections portfolios.
        • Understand the reporting and analysis tools available in the company loan systems and provide management and the IT coordinator with requirements for additional functionality.
        • Maintain strict confidentiality of all customer data within the department.


Job Requirements

  • Candidate will have extensive centralized collections and loan servicing management experience.
  • Candidate must be a leader and team builder including team member selection, training, and coaching performance enhancement.
  • Candidate must manage for results in cost control of the operation, customer retention, dollars collected and performance to on time payment and ultimate loss standards of the company.
  • Candidate must build, maintain and personally exhibit a compliance culture with company policies, goals and procedures as well as applicable Federal and State law and regulation.
  • Candidate must maintain confidentiality of customer information and build a culture of confidentiality within the loan servicing area.
  • Candidate must be up to date on technology applicable to this function, its selection, implementation, management and use to achieve results.
  • Candidate must be professional in appearance and bearing and expect the same of subordinates.
  • Candidate must be results oriented.
  • Candidate must possess oral, written and electronic communications skills and a basic understanding of social media.
  • Candidate must be a self-starter and able to carry out goals with a minimum of supervision.
  • Candidate will demonstrate intelligence, leadership, results orientation in all past work experiences.
  • Candidate will pass a rigorous background check and will have not have had a history of substance abuse.

We’re in the $70K – $85K salary range in a state in the South East!

Apply here:


Tom Nix: Nixland, My Wild Ride in the Inner City Check Cashing Industry

Check Cashing Tom Nix NixlandTom Nix’s “Nixland” is just as its title states, “My Wild Ride in the Inner City Check Cashing Industry.” I laughed out loud many times as I read Tom’s exploits in the “loan shark industry.” In polite society, we refer to it as (AFS) Alternative Financial Services. Payday loans, car title lending, check cashing…

Tom’s descriptions of growing up in San Pedro, his first days at USC and his altercation with Coach John McKay, his Los Angeles County Sheriff experiences, ramping-up his family’s check cashing business into a California powerhouse for serving the inner city by providing jobs and opportunity – all the while achieving PROFITS (an ugly word for many), leave no doubt that the time you “invest” in “Nixland” is a 100% ROI.

“Nixland” is a real world example of what a singular minded entrepreneur can accomplish in any vertical, albeit highly controversial. Not only will the reader find this book impossible to put down, but, you’ll be inspired, more business savvy, and optimistic regarding what can be accomplished through hard work and determination.

I’m proud to be a member of the AFS industry and I’m extremely glad I discovered ‘Nixland!”

Here’s a link to Tom’s book and no, it’s not a mickey-mouse Amazon affiliate link :o)

Jer – Trihouse