THE BLOG

10
Jul

Questions Payday Loan Customers Ask Lenders

We quizzed 94,577 consumers who either currently have or at 1X+ had a payday loan, title loan, or a non-collateralized installment loan.

As a lender or vendor or lawyer in the “Business of Lending Money to the Masses,”

YOU need to know what their #1 questions are. For the answers, invest in our 2019 Course. Click Here!

So, here you go:

  • How do I qualify?
  • What do I need to get a payday loan?
  • Where are you?
  • How can I get rid of payday loans legally?
  • Can you go to jail for not paying back a payday loan?
  • How can I avoid paying payday loans legally?
  • How can I stop a payday lender from electronically taking money out of my bank or credit union account?
  • How can I avoid paying payday loans legally?
  • What happens if I can’t pay my payday loan?
  • What happens if I can’t pay my payday loan?
  • How can I get rid of payday loans fast?
  • How to get out of payday loan debt?
  • How can I get rid of payday loans fast?
  • How can I settle my payday loan?
  • Payday loan settlement – Is it a good legal option to settle my payday loan?
  • How can I settle my payday loan?
  • Can they garnish your wages for a payday loan?
  • Is there a statute of limitations on payday loans?
  • Can I get a warrant for a payday loan?
  • What happens if you stop paying payday loans?
  • How can I stop my payday loans?
  • Can I stop paying payday loans?
  • Can’t afford to pay back payday loans?
  • Can a payday loan sue you after 7 years?
  • Do I have to pay back an illegal payday loan?
  • How do I get out of a payday loan cycle?
  • Are Payday Loans Bad?
  • How can I get a payday loan without a bank account?
  • Can I negotiate with payday lenders?
  • How can I get out of payday loan debt?
  • Can debt relief help with payday loans?
  • How can I stop payday loan garnishment?
  • How long can a payday loan be collected?
  • What happens if a payday loan check bounced?
  • Can I be chased for debt after 10 years?
  • How long does a payday loan stay on your credit?
  • Do debt collectors ever give up?
  • Can you go to jail for not paying a payday loan?
  • Can you go to jail for not paying a loan company?
  • How can I get rid of payday loans legally?
  • How can I get out of paying my payday loans?
  • Can I get a payday loan if I owe one?
  • Are payday loans illegal?

Jer – Trihouse 702-208-6736  For a copy of this report in PDF format delivered to your Inbox, send an email to: TrihouseConsulting@gmail.com

To schedule a strategy/exploration call, click to view my calandar Clarity.fm

How to start a payday loan, car title loan installment loan company

Course: How to Lend to the Masses

Click Here: $337.00 Immediate PDF Download


If you’re worn out spending hour upon hour searching Google for consumer loan business strategies, know-how, software, licensing, consumer credit reporting, sample contracts, collection tactics, profitability, how much start-up capital you need, anticipated default metrics, and on and on and on… Our “Bible” delivers ALL THESE ANSWERS AND MORE!

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08
Jul

CFPB Update: Payday, Vehicle Title, & Installment Lending Rule

PaydayLoanIndustryBlog.com      702-208-6736

CFPB Update: Payday, Vehicle Title, and High-Cost Installment Lending Rule: Payment-Related Requirements

Small Entity Compliance Guide

Table of contents

1. Introduction

1. Scope and focus of this guide

2. A brief summary of Payday Lending Rule’s payment-related requirements, effective date, and the compliance date

3. Use of examples in this guide

4. Additional implementation resources

2. Covered loans

1. Covered short-term loans

2. Covered longer-term balloon-payment loans

3. Covered longer-term loans

4. Exclusions from coverage

5. Conditional exemptions

3. Lenders and service providers under the Payday Lending Rule

1. Lenders

2. Service providers.

4. Prohibited payment transfer attempts

1. Payment transfers

2. Conditional exclusion for certain transfers made by an account-holding institution

3. Exception for additional payment transfers authorized by the consumer in a new and specific authorization

4. Single immediate payment transfers at the consumer’s request

SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE: PAYMENT-RELATED REQUIREMENTS

Prohibition on evasion

Disclosure of payment transfer attempts

General form and delivery requirements for notices

1. First payment withdrawal notices

2. Unusual payment withdrawal notices

3. Consumer rights notices

4. Electronic short notices.

Compliance program and record retention

1. Compliance program

2. Record retention

3. Prohibition on evasion

Payday Loans, Title Loans Installment Loans: CFPB

Payday Loans, Title Loans Installment Loans: CFPB

1. Introduction

On October 5, 2017, the Consumer Financial Protection Bureau (Bureau) issued a final rule governing certain personal loans with short-term or balloon-payment structures and certain additional installment loan products (2017 Payday Lending Rule).

On February 6, 2019, the Bureau issued: (1) a notice of proposed rulemaking to reconsider the 2017 Payday Lending Rule’s mandatory underwriting provisions;(1)and (2) a notice of proposed rulemaking to delay the August 19, 2019 compliance date of the mandatory underwriting provisions.

On June 6, 2019, the Bureau issued a final rule (Delay Final Rule)3 finalizing the second of these two proposals. The Delay Final Rule delays the August 1 9, 201 9 compliance date for the 2017 Payday Lending Rule’s mandatory underwriting provisions to November 19, 2020, and makes technical corrections to the 2017 Payday Lending Rule.

This guide uses the term “Payday Lending Rule” or “Rule” to refer to the 2017 Payday Lending Rule as amended by the Delay Final Rule.T he proposed rulemaking does not reconsider the payment-related requirements of the Payday Lending Rule. Thus, this guide highlights information that may be helpful when implementing the payment-related requirements of the Payday Lending Rule. It does not discuss the Rule’s mandatory underwriting provisions. As appropriate, the Bureau will revise this guide to assist.

SMALL ENTITY COMPLIANCE GUIDE: PAYDAY LENDING RULE: PAYMENT-RELATED REQUIREMENTS

An industry with the implementation of the Payday Lending Rule’s mandatory underwriting provisions at a later date. This guide meets the requirements of Section 21 2 of the Small Business Regulatory Enforcement Fairness Act of 1996 with regard to the Payday Lending Rule’s payment-related requirements. This guide is not a substitute for reviewing the Payday Lending Rule. The Payday Lending Rule and its Official Interpretations (also known as the commentary) are the definitive sources of information regarding the Payday Lending Rule’s requirements. The Payday Lending Rule is available.

cfpb_payday_small-entity-compliance-guide-07-08-19
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07
Jun

Consumers Rejoice! CFPB Issues Final Rule on Payday Loan Underwriting

More good news for USA households as the CFPB recognizes access to credit for all at competitive rates is preferable to zero financial choices!

On June 6, 2019, the Bureau issued a final rule delaying the August 19, 2019 compliance date for the Mandatory Underwriting Provisions of the 2017 Payday Lending Rule to November 19, 2020.

June 6, 2019

Executive Summary of Delay Final Rule’sAmendments to the 2017 payday lending Rule

On June 6, 2019, the Consumer Financial Protection Bureau (Bureau) issued a final rule (Delay Final Rule) delaying the compliance date for the Mandatory Underwriting Provisions of the Bureau’s 2017 rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans (2017 Payday Lending Rule).

The Delay Final Rule also makes certain technical corrections to the 2017 Payday Lending Rule.

This executive summary provides an overview of the Delay Final Rule but is not a substitute for reviewing the Delay Final Rule itself.

Background On October 5, 2017, the Bureau issued the 2017 Payday Lending Rule to establish regulations for payday loans, vehicle title loans, and certain high-cost installment loans.

The 2017 Payday Lending Rule addressed two discrete topics.

First, it contained a set of provisions with respect to the underwriting of certain covered loans and related reporting and recordkeeping requirements. These provisions are referred to herein as the “Mandatory Underwriting Provisions.”

Second, it contained a set of provisions establishing certain requirements and limitations with respect to attempts to withdraw payments from consumers’ checking or other accounts and related recordkeeping requirements. These provisions are referred to herein as the“Payment Provisions.”

The Bureau also provided an unofficial redline and an executive summary.

How to start payday loan business, title loan business, loan business
Click Here: $337.00 Immediate PDF Download


Click this link Course #1 for a complete Table of Contents.

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25
May

42,000,000 Adults Over 50 In Deep Financial Trouble in Need of Creative Loan Products

A quick scan of the media headlines leads the average reader to conclude all is well in the U.S. economy.

42,000,000 U.S adults 50+ years old are BROKE! Did they count the homeless?

Hell, if you’re in the business of lending money to the masses, you might conclude that you should shut the doors, layoff all your employees, and open a yogurt shop.

Then, there’s this: The Center for Financial Services Innovation (CFSI), the “nation’s authority on consumer financial health,” together with AARP Foundation, a “national leader in the fight to end senior poverty,” announced the release of a new report based on the U.S. Financial Health Pulse report data that shows 83 percent (42 million) of the estimated 50 million low- to moderate-income people over the age of 50 (LMI 50+) living in America are struggling with some or all of the components of their financial lives.”

how to start a payday loan company

How to Start a Loan Biz

According to the press release, this report, “Redesigning the Financial Roadmap for LMI 50+ Segment: New Challenges and Opportunities,” offers an in-depth look at the increasing financial insecurity of LMI 50+ and the major factors contributing to a more complex financial reality for them than for past generations.

This study revealed that the 50+-year-old demographic want to retire but can’t; they’re broke!

The bottom line according to this Report? It’s a B&*(((tch when you hit 50! No savings. Loss of home in 2008 – renting now, living with kids and grand-kids, medical issues [obesity]…

There was even an expose in I believe the NYT that revealed seniors are “on the hook” for their children’s student debt because Grandma co-signed. [Are you aware student debt cannot be discharged in a bankruptcy?]

The report identified specific financial challenges facing the LMI 50+:

The Report summed up:

  • More than half (51%) have liquid savings of less than three months of expenses, and only a quarter (26%) have an emergency savings account.
  • More than 6 in 10 (61%) indicate they don’t have savings in an employer-provided or individual retirement account. For those with savings in either account, the median amount is $20,000, far less than recommended for a comfortable retirement.
  • The vast majority (81%) have some amount of debt, with half (48%) reporting their debt isn’t manageable.
  • More than a third (36%) with debt report that their debt has delayed or prevented them from saving for retirement.

LMI 50+ Medical Shocks & Multi-generational Living

  • Overall, 38% had to forgo health care or medication in the past year because they couldn’t afford it.
  • Nearly a third (31%) indicate they’re supporting someone financially who lives outside of their household.
  • Households of three or more people report having higher financial stress (87%) than households with one or two individuals (82%). Of households with three or more people, 83% report that their financial stress leads to negative impacts on their family life.

Why is this important to you?

OPPORTUNITY! These folks need a multitude of loan products that work for them. The LMI 50+ demographic is invisible to the majority of lenders in the marketplace today

The Report goes on to state, this LMI 50+ Demographic:

  • Are open to using digital technology to manage aspects of their financial lives.
  • Appreciate being able to monitor transactions and pay bills online.
  • Care about security, but not in a way that limits the use of technology.
  • Desire relevant, actionable financial education and coaching for everyday financial management.
  • Use technology-centric innovations, but have different levels of comfort with high-tech vs. high-touch engagement.

FINALLY, for all my PC [that’s politically correct] readers, rather than attack check cashers, pawn shops, small-dollar lenders… while locking your gate-guarded community entrance tight, [Don’t look at me! We have a bridge, not a gate.] build a team, create a loan product that you define as fair, make some $$, give back to your community and help a little! PS: Don’t leave banks and credit unions out of your attacks! They are not the answer! And then, there are the money transfer businesses working with these banks who charge as much as $25 in fees to transfer $100 to El Salvador, the Philippines… Go Ripple, Bitcoin, Stellar, EOS… Crypto.

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22
May

Operation Choke Point: FDIC Surrenders to Payday & Small Dollar Loan Industry

Great news for “the business of lending to the masses!” Thanks to the heavyweights in our industry, Advance America and Check Into Cash, consumers continue to win. Consumer access to a multitude of choices when dealing with temporary financial setbacks prevails.

“We uncovered how some FDIC leaders and officials executed a campaign motivated by personal scorn for our industry, contempt for our millions of customers, and blatant disregard for due process. This settlement will help to prevent this disenfranchisement from happening again – to our business or any other legal, regulated business.” Chief Legal Officer Jessica Rustin, Advance America.

It took 5 years but “Operation Choke Point” has been dealt a SEVERE blow. 

Consumers, lenders, and vendors all owe a HUGE thank you to these companies and those of you who support the industry associations and participated on this long, arduous, expensive journey!

SPARTANBURG, S.C.PRNewswire/ — Advance America and Check Into Cash announced today that they have reached a settlement with the Federal Deposit Insurance Corporation (FDIC) regarding Operation Choke Point, the FDIC program that pressured banks to cut ties with certain categories of lawful businesses, including payday lenders.

“Five years after taking the extreme and costly step of suing federal regulators, we are pleased with the FDIC’s actions to address past efforts to cut off our companies’ access to the U.S. banking system,” said Jessica Rustin, Advance America’s Chief Legal Officer. “We uncovered how some FDIC leaders and officials executed a campaign motivated by personal scorn for our industry, contempt for our millions of customers, and blatant disregard for due process. This settlement will help to prevent this disenfranchisement from happening again – to our business or any other legal, regulated business.”

As a result of this settlement agreement, the FDIC will issue a statement to reiterate its policies. The FDIC previously acknowledged that certain employees acted in a manner inconsistent with FDIC policies and existing guidance with respect to payday lenders, creating misperceptions about its policies. These attempts have proven ineffective in resolving the issue.

The steps taken as part of this settlement are consistent with statements made by FDIC Chair Jelena McWilliams, who declared in a letter to members of Congress earlier this year that “[r]egulatory threats, undue pressure, coercion, and intimidation designed to restrict access to financial services for lawful businesses have no place at this agency.”

“While the FDIC took steps to reinforce its policies with staff and the industry, the effects of Operation Choke Point linger, with banks continuing to terminate accounts and refuse services to payday lenders,” said Greg Madson, Chief Legal Officer at Check Into Cash. “It is our hope that this settlement clarifies once and for all the FDIC’s policies so that banks feel free to provide services to lawful businesses operating in compliance with applicable federal and state laws, without fear of regulatory pressure or retribution.”

The FDIC will conduct training of its examination workforce on these policies by the end of 2019 to ensure that its examiners adhere to the highest standards of conduct and respect the rule of law. The training will specifically include matters related to Operation Choke Point.

Lastly, the FDIC has established a robust complaint process through which information regarding potential violations of these policies may be investigated. If banks or customers continue to be concerned that FDIC personnel are not following the FDIC’s policies regarding Operation Chokepoint, they may email the FDIC at transparency@FDIC.gov.

In June 2014, the Community Financial Services Association of America (CFSA), the national association for small-dollar lenders, joined industry partners and its largest member companies, Advance America and Check Into Cash, to file the lawsuit, Advance America et al. v. Federal Deposit Insurance Corp. et al., to end Operation Choke Point and the government’s persistent regulatory overreach. Discovery exposing depositions and damaging emails of government officials, most notably at the FDIC, was released in October 2018 as part of the Plaintiffs’ Motion for Summary Judgment in the lawsuit. The settlement is the result of court-ordered mediation prior to a judge’s ruling on summary judgment.

“Certain FDIC officials operated well outside of the rule of law and disregarded due process when they targeted lawful businesses under Operation Choke Point,” said Dennis Shaul, CEO of the Community Financial Services Association of America (CFSA). “Regulatory policy must never be predicated on personal preferences and this settlement should make clear that such abuses of power will not be tolerated.”

About Advance America Cash Advance 
Founded in 1997, Advance America, Cash Advance Centers, Inc. is the country’s leading provider of non-bank cash advance services, with approximately 1,900 centers across the country. The Company is a founding member of the Community Financial Services Association of America (CFSA), whose mission is to promote laws that provide substantive consumer protections and to encourage responsible industry practices. Please visit www.AdvanceAmerica.net for more information.

About Check Into Cash 
Founded in Cleveland, Tennessee in 1993 by entrepreneur and philanthropist Allan Jones, the Check Into Cash brand is a state licensed and regulated small balance lender. Check Into Cash stores offer check cashing, Western Union® money transfers, prepaid U.S. Money Cards, and other convenient services as a complete One Stop Money Shop®.

Check Into Cash is a founding member of the Community Financial Services Association of America (CFSA), the trade association representing the nation’s payday lenders. The CFSA advocates for best practices and helps enact legislation that balances the needs of the consumer with the interests of the industry.

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