CRL’s report also calls for regulators to take immediate actions to stop banks offering payday loans from engaging in this form of predatory lending. Additionally, CRL calls for the following terms on small loan products:
•A minimum loan term of 90 days with affordable installments;
•An APR of 36 percent or less;
•Underwriting based on an ability to repay; and
•No mandatory automatic repayment from the consumer’s checking account.
More than a year ago, 250 organizations and individuals sent a letter to federal banking regulators expressing concerns about bank payday lending. Last year, in a separate action, more than 1,000 consumers and organizations told the Consumer Financial Protection Bureau about elder financial abuse, including bank payday lending.
At that time, CRL advised, “More than 13 million older adults are considered economically insecure, living on $21,800 a year or less. Senior women in particular face diminished incomes because of lower lifetime earnings and therefore lower Social Security and pension benefits.”
As opposition to bank payday and elder financial abuse grows, banking regulators are continuing to hear from advocates, experts and concerned citizens. Fortunately, advocates are determined to press this issue in growing numbers. In a letter dated March 13, for example, 278 organizations and individuals signed a second letter to regulators.
The letter states, “Payday lending has a particularly adverse impact on African-Americans and Latinos, as a disproportionate share of payday borrowers come from communities of color. High-cost, short-term balloon repayments, and the consequent series of repeat loans, have long been identified by regulators as features of predatory lending.
“Ultimately, payday loans erode the assets of bank customers, and rather than promote savings, make checking accounts unsafe for many customers. They lead to uncollected debt, bank account closures, and greater numbers of unbanked Americans. All of these outcomes are inconsistent with both consumer protection and the safety and soundness of financial institutions.”
The limitation of space will not allow for the listing of all 278 signatories. But they include many national and statewide organizations, including AARP, AFL-CIO, AFSCME, the Black Leadership Forum, NAACP, the Leadership Conference on Civil and Human Rights and CRL.
The coalition warns, “Please move quickly to ensure that payday lending by banks does not become more widespread and to ensure that those banks currently making payday loans stop offering this inherently dangerous product.”
(Charlene Crowell is a communications manager with the Center for Responsible Lending. She can be reached at: Charlene.firstname.lastname@example.org)