By Krisztina Pusok
Most Americans take access to credit for granted. Recent estimates show that there were 364 million open credit card accounts in the United States as of the end of 2017, with about 7 in 10 Americans having at least one credit card.
But for consumers with poor credit histories and credit scores lower than 580, such credit options aren’t even on the table. About 12 million of these people turn to small-dollar credit services to make ends meet. Surprisingly, until recently, the federal government was threatening to take this option away from them.
The Consumer Financial Protection Bureau (CFPB) recently proposed to re-examine the small-dollar lending rules created under the Obama Administration in 2017 — which were set to go into effect this year.
The CFPB, under its new director, now says there was “insufficient evidence” the proposed rule was protecting consumers. Worse, there were signs that it actually would decrease competition in the industry and reduce access to credit for consumers who use small-dollar and short-term loans, such as payday, single-payment vehicle title, and longer-term balloon payment loans.
The CFPB’s decision generated some loud criticism. Here is why it’s in the interest of the underserved and vulnerable consumers.
The CFPB’s own report published in 2016 predicted that if the rule took effect, “payday loan volume and revenues would decline between 60% and 82%.” This would translate to denying many of the most vulnerable consumers the only viable option to access credit.
One survey found that ninety-five percent of small dollar borrowers say that payday lending should be a choice available to them, and believe that small-dollar loans provide a safety net during unexpected financial trouble. Losing access to credit is harmful to any consumer, regardless of their income. But what do you do when one of the few options to capital is taken away from you?
When you’re in a short-term pinch for cash, small-dollar loans are often a better and faster option than the available alternatives, such as overdrawing a bank account, defaulting on a different loan, or even resorting to illegal activities. All of these other options imply high implicit charges. For consumers with low credit scores, getting a loan from a bank is not even an option.
The demand for small-dollar loans won’t disappear, but the burden on vulnerable consumers would not decrease either. The burden goes beyond the sensibilities of the average consumer and can make life much harder in the long run. Imagine having to skip a doctor’s visit, bouncing a check for a utility bill or even rent, or not being able to provide your children’s next meal. These are all burdens that low-income consumers who rely on small-dollar loans frequently confront.
Although these vulnerable borrowers face short-term financial obligations, they do their research when deciding for a small-dollar loan by considering other credit options available to them. As a recent study shows, payday loan applicants, for example, had an average of five credit option inquiries during the 12 months before taking out a loan, three times higher than that of the general population.
The CFPB is right to be worried that its small-dollar rule would harm those who most need a hand up: low-income consumers. After all, it is the Bureau’s job to educate and protect all consumers.
Instead of focusing on how to limit specific options to access credit, the government should spend at least the same effort on promoting the development of new technologies that facilitate the development of products and services that improve financial access for the underserved consumers, as well as educating consumers on finance and budgeting.
It’s easy for most of us to take access to credit for granted and enjoy access to a multitude of credit options, but for the 12 million Americans that are not thinking about adding an Amazon or Apple credit card to their wallet, small-dollar loans are one of the few solutions available to invest, grow, and sometimes even survive.
Dr. Krisztina Pusok is the Director of Policy and Research with the American Consumer Institute Center for Citizen Research, a 501(c)(3) nonprofit educational and research institute. For more information about the Institute, visit www.TheAmericanConsumer.Org or follow us on Twitter @ConsumerPal.
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Payday, car title, and similar loan providers charge very high interest. However these are RISKY loans: The people who need them are already in financial trouble and while some will climb out during the term of their loan, others won’t. If the interest rates don’t reflect the risk nobody’s going to be in that business.
It’s not a favor to make laws that make living on the edge even tougher. The federal government ought to stay out of this area — let the states make and enforce laws requiring honest dealing.
Sign on the wall where I bought the car I’ll be driving today: “Want to get back on your feet fast? Just miss a couple of payments!” Fine machine … ’bout to turn a quarter million. We paid cash but glad that others have other options.
There’s pros and cons to these payday loans. My wife and I helped some close friends of ours that were overwhelmed with payday loans. They were paying $2,000 (sum of many smaller payments) per month to multiple companies for $25k in loans. Their payment is now under $600 and will be paid off in a few years instead of paying 2k for an eternity. The payday loan companies never reported to credit agencies, so their credit scores never went up for making on-time payments. Had their scores been increasing, they could have gotten a real loan before racking up 5k in payday loan debt.
The loan companies should have to report scores, and banks/credit scoring companies should be wise to individuals making $1,500-$2,000 in payments to payday lenders, and that those individuals should probably qualify for a signature loan even if they’re late on a $200 payment here and there. If a person is struggling and can only pay $1,800 of $2,000 in payday loans, it doesn’t mean they can’t easily afford a $500-$1,000 payment.