July 16, 2018
by Ben Morales, QCash CEO
While the financial services industry and its regulators debate what is the right APR for short-term, small-dollar loans, Americans in need of relief wait. Their waiting comes with a cost – a big one. PEW Charitable Trusts estimates U.S. consumers spend $9 billion annually on small-dollar loan fees. There is a number already vetted that would encourage more institutions to offer short-term credit at reasonable rates for consumers in need: 36. It’s time to stack hands on 36% APR and start helping more consumers get out of the debt trap.
Many advocates are already on board with the concept.
The National Consumer Law Center (NCLC) conducted research on how a 36% APR has legitimacy as a price point. They show that it would be a win-win for consumers offering access to affordable credit and would allow financial institutions to earn sustainable revenue to offer the loans.
Then there’s the FDIC pilot on small dollar lending that tested the 36% APR. Additionally, the Center for Responsible Lending has stated its position that a 36% APR cap on payday loans most effectively stops the cycle of debt.
The Consumer Financial Protection Bureau’s most recent proposal would require lenders to underwrite payday and short-term small-dollar loans to ensure they are affordable to consumers. To avoid the stiffest requirements, such as assessing a borrower’s ability to repay a loan, installment lenders can opt for an alternative that effectively caps the rate at 36%.
Regulators state they want more lenders in the short-term loan market to help consumers; however, we already know the low success rate of expanding small-dollar lending at lower APRs. The NCUA allows for a 28 percent APR cap on small-dollar loans for federal credit unions, but it hasn’t generated much participation. In fact, fewer than 18 percent of credit unions offer these products today. The reason is that many justifiably believe they cannot create a financially sustainable short-term loan program with the 28 percent APR cap. That leaves tens of millions of credit union members lacking for a source of short-term credit without turning to predatory lenders.
The 36% APR is the sweet spot. And it’s already been tested and used for more than a decade. After all, it’s been the price point cap for small-dollar loans for military service members since 2006 as established by the U.S. Congress.
Yet here we remain in 2018 with no universal agreement on how to move forward in a balanced way. A 36% APR can work. Q-Cash Financial has delivered a fully automated digital small dollar lending platform for over 15 years to substantiate that a 36% APR is feasible. It’s feasible with the right automation. It’s feasible with the right underwriting criteria. It’s feasible with a true dedication to helping consumers caught in the struggle of everyday life.
As an industry, despite our best efforts and most polished mission statements, we often don’t fully understand the scarcity mindset of consumers caught trying to navigate their day-to-day financial lives. Helping cash-strapped consumers bridge a gap should be our calling as lenders, not just their problem as borrowers.
Let’s rally as an industry and collectively support a 36% APR as the right way and the only way we are going to deploy a sustainable product that challenges the predatory lending marketplace to drive prices down for borrowers.
It’s time to speak out and support a 36% APR on short-term, small-dollar loans. Anything less, leaves millions of Americans with no other choice but to use predatory lenders.
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