Letter to Bank Regulators: Stop Bank Payday Lending

Letter to Bank Regulators: Stop Bank Payday Lending

Some 250 advocates urged four federal regulators to get rid of the predatory practice of bank payday lending on February 22, 2012. The CFPB, OCC, FDIC and Federal Reserve Board can and may stop Wells Fargo, United States Bank, Fifth Third Bank and areas Bank from trapping their customers in long-term financial obligation at 400per cent yearly interest.

The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1500 Pennsylvania Ave. NW Washington, DC 20220

The Honorable Ben S. Bernanke Chairman Board of Governors, Federal Reserve System Street that is 20th and Avenue, NW Washington, DC 20551
Mr. Martin Gruenberg Acting Director Federal Deposit Insurance Corporation 1776 F Street, NW Washington, DC 20006 Mr. John Walsh Acting Comptroller workplace associated with the Comptroller regarding the Currency 250 E Street, SW Washington, DC 20219

cc: The Honorable Sarah Bloom Raskin, The Honorable Elizabeth A. Duke, The Honorable Daniel K. Tarullo

Dear Chairman Bernanke, Director Cordray, Acting Chairman Gruenberg, and Acting Comptroller Walsh:

We compose to urge the federal regulators of y our nation’s banks to simply just just take instant action to stop banking institutions from making unaffordable, high-cost payday advances.

Wells Fargo, United States Bank, Fifth Third, areas, and Guaranty Bank’s deposit “advance” loans are organized similar to loans from pay day loan stores – carrying a high-cost along with a balloon repayment that is short-term. Studies have long shown why these loans trap borrowers in a period of high priced long-term financial obligation, causing severe monetary problems for borrowers, including increased possibility of bankruptcy, spending bank card debts as well as other bills belated, delayed health care, and lack of basic banking privileges due to duplicated overdrafts.

Further, payday financing by banking institutions undermines state legislation in the us which have prohibited or imposed meaningful limitations on payday advances in the last few years, or which have never ever allowed pay day loans to engage in their market. It undermines conditions associated with the Military Lending Act directed at protecting solution users from payday advances.

The banks will advance the pay in increments for a fee, ranging from $7.50 to $10 per $100 borrowed for customers with direct deposit of wages or public benefits. The lender deposits payday loans online in Virginia the mortgage quantity straight into the customer’s account after which repays it self the mortgage quantity, and the cost, straight through the customer’s next incoming deposit that is direct. The bank repays itself anyway, even if the repayment overdraws the consumer’s account, triggering more costs through overdraft fees if direct deposits are not sufficient to repay the loan within 35 days.

Non-bank payday borrowers routinely end up struggling to repay the mortgage in complete plus satisfy their costs for the month that is next taking right out another pay day loan. A current analysis of real bank account task because of the middle for Responsible Lending [i] discovers the exact same holds true with bank payday advances:

Bank payday advances typically carry a percentage that is annual (APR) of 365 % in line with the typical loan term of ten days;[ ii]

On average, bank payday borrowers have been in financial obligation for 175 times per year;[ iii]

Numerous borrowers take out ten, 20, if not 30 or higher bank payday advances in a year;[ iv]

Numerous bank payday borrowers are Social protection recipients, plus the banking institutions just simply just take significant portions of these month-to-month checks straight away for payment of bank payday advances.[v]

These findings further prove that, such as the storefront context that is payday lender “protections” like “installment choices” and “cooling down durations” just usually do not stop the period of perform loans.

You will find clear signals that bank payday lending will grow rapidly without prompt regulatory action. Fiserv, Inc., a provider of computer pc computer software systems to your industry that is financial has continued to develop a bank payday pc computer software item it calls “Relationship Advance.” Fiserv is reporting interest that is significant the item: “The pipeline is very strong. We’ve had some good mid-tier signings over the past three, four months and then we see this as an appealing driver of … high-quality revenue that is recurring. ”[ vi]

Fiserv’s marketing of this Relationship Advance product has included promises that, within couple of years, revenue through the item “will be higher than all ancillary charge income combined”[ vii] and that the item can lead to little-to-no “overdraft revenue cannibalization;”[ viii] in other words, it’s going to include another high charge supply without reducing overdraft charge income.

Finally, pay day loans erode the assets of bank customers and, as opposed to market cost cost savings, make checking accounts unsafe for several clients. They result in debt that is uncollected banking account closures, and greater amounts of unbanked Us americans. Many of these results are inconsistent with both customer security plus the soundness and safety of banking institutions.

Please go quickly to ensure payday financing by banking institutions will not be a little more extensive, and also to make certain that those banking institutions presently making pay day loans stop offering this product that is inherently dangerous.

We appreciate your consideration of y our issues.

AFL-CIO People in the us for Financial Reform Center for Responsible Lending Church of England Ethical Investment Advisory Group customer Action customer Federation of America people Union Demos First Nations Development Institute Green America Jesuit Conference Jewish Reconstructionist Federation Leadership Conference for Civil and Human Rights principal Street Alliance Missonary Oblates, US Province NAACP nationwide Advocacy Center for the Sisters for the Good Shepherd National Association of Consumer Advocates nationwide Community Reinvestment Coalition National Consumer Law Center (on the behalf of its low income consumers) nationwide Fair Housing Alliance National People’s Action SYSTEM, A national Catholic personal Justice Lobby Mercy Investment solutions Pax World Funds PICO nationwide system Progressive resource Management Responsible Endowments Coalition SEIU 32 BJ Sisters of Charity for the Blessed Virgin Mary Sojourners The Greenlining Institute Trillium Asset Management United Church of Christ Justice and Witness Ministries US PIRG