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Director Cort 3 I know the CFPB is close to issuing it's payday lending rules so I want to ask you 3 questions about Payday Loans Help. Can you describe the research and data gathering that the CFPB has done to try to figure out where to draw the line.

Between preserving access to credit and trapping people in never ending cycles of payday loans yes so here as with arbitration we've engaged in the most comprehensive research ever done by anyone on this marketplace we've done too significant white papers analyzed millions.

Millions of payday loans across all types of lenders are and what we found is that the model here is to. In particular it on unpaid a balloon loans is to get someone into a paid a balloon long. And if they had to borrow $300 today the notion they're gonna be able to repay 3 earned $45 2 weeks from now is not very likely although some do and and great for them and maybe it works for them but many others end up rolling it over and rolling over because they can pay the $45 at the end of the 2 weeks but they can't pay the 3 or 45 and they can never pay the threat of 45 and by the way you describe these products as 2 or 3 or 4 percent interest rates.

In Missouri we have seen products US loan products that go as high as 1950 percent rate of interest you can actually land out where the fees amount to 75 percent the face value of the loan that's a $1000 loan that becomes. 18000 or $20000 by the end of the first year. And goes on from there and this is from a class action decision by a Missouri appellate court in which they read out of the record some of the actual instances of people who guard $100 and ended up paying back thousands of dollars and still owing thousands of dollars that is not a recipe for financial success for for people yeah thank you very much all let me ask a second question around this. States currently have different standards for regulating small dollar lending but the CFPB would create a single national floor.

It's true of securities law it's true of environmental law it's true of antitrust law a it's true in in many different areas of law where the federal government may intervene to a certain degree and set a certain requirements on individual citizens and companies the states are free to have their own regimes and they do and they set requirements on individuals and companies and the 2 systems coexist this is there's nothing unusual about this it's it's been described as cooperative federalism and it and it works reasonably well it can be a little complicated at times I suppose but a federal system is is bound to be a little complicated at times alright good thank you and let me ask my third question here the CFPB he's been working in this area now for 3 years you've been gathering data as you've described drafted different approaches talked about it with industry.

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Now certain members of Congress have proposed imposing an additional 2 year delay on your efforts. Can you give us some idea about the impact of that delay and estimate how many more families will get stuck in a debt trap during that time.

So I feel keenly already the amount of time that it takes to embark on a federal rule making in an area that is a baseline of no out research previously it's taken several years to do the kind of detailed research that you asked me about and I described a it is taking its time to go through the process is in our statute including a small business review panel and report and so forth I and we are now on the verge of. Actually proposing the were cool and it will take time to work through it and finalize it up.

I feel keenly that that every day that passes if you think a rule is going to improve life and it may or may not but if you think it is going to improve life is like that to happen as soon as possible and delay for delays sake simply means that if they're harms here and our research has identified harms to consumers then they will go on. Anybody should feel like that's no big deal means that they they simply disagree with with the findings around the country of what this does for people and for families and and like I can't I can't agree with that right for Tiger perpetuating a lot of misery here yes that's what I want to thank you I want to thank all the people who work at the CFPB for their terrific efforts in this area you know I know that the payday lending industry hires a lot of lobbyists and they make a lot of political contributions.

Try to protect their multi $0 business I also know that families they get cheated by payday lenders don't have lobbyists and they don't have political action committees. Which is why the independence of the CFPB is so important. You know I hope you will move quickly to complete your rule making on payday loans you are the best hope. For millions of American families to avoid these debt traps in the future thank you for your work.