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Advocacy & Analysis. We advocate for customers against high-cost finance anywhere it crops up. See a few of our work below.

By on July 17, 2021
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Advocacy & Analysis. We advocate for customers against high-cost finance anywhere it crops up. See a few of our work below.

Reinvestment Partners presented these reviews to your workplace regarding the Comptroller associated with the Currency as well as the Federal Deposit Insurance Corporation in reaction for their joint approval to permit their user banking institutions to make use of their charters to evade state anti-usury guidelines. The proposition, if authorized, allows banking institutions to disregard state laws that put ceilings on rates of interest. New york includes a strong state guideline that caps interest levels at 30 %. Underneath the “Rent-a-Bank” model, since it was described, banking institutions could mate with payday loan providers to provide loans with interest levels in excess of 200 %.

Reinvestment Partners submitted this remark into the workplace regarding the Comptroller regarding the Currency regarding the agency’s proposition generate a special-purpose charter that is national fintech businesses.

In crafting this remark, Reinvestment Partners partnered with all the Maryland Consumer Rights Coalition to convey our typical concerns that this charter could eviscerate the state that is strong protection legislation which can be currently in position in our particular states. Provided our presumptions that the OCC may get ahead using their plans, we additionally taken care of immediately their particular questions on what this type of regulatory scheme would enhance monetary addition for under-served customers.

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Reinvestment Partners submitted this remark to your customer Financial Protection Bureau on November 7th, 2016. The Bureau asked for remarks as to how items offered regarding the payday advances, automobile title loans, installment loans, and open-ended credit lines might undermine customers.

This RFI follows regarding the Bureau’s current rulemaking on payday, car name, and specific installment loans. Reinvestment Partners also presented a touch upon that rule-making. In this remark, Reinvestment Partners concentrated upon our issues connected with credit insurance, deferred interest contracts on installment loans, and insurance that is non-file.

In its touch upon third-party financing, Reinvestment Partners urged the FDIC to ascertain a framework that is strong relationships between its insured organizations and non-bank loan providers. We have been worried why these plans pose the potential to undermine state usury legislation.

The FDIC has proposed a definition of these tasks which will protect almost all of the brand new innovations in this room, but our remark advises that the approach that is new capture a few of the associated advertising approaches. Throughout, we urge the FDIC to prioritize the chance of these items to carry injury to customers.

Reinvestment Partners submits these feedback in collaboration utilizing the Woodstock Institute (IL), the California Reinvestment Coalition, plus the payday loans Colorado Maryland Consumer Rights Coalition.

Reinvestment Partners submits this touch upon the CFPB’s Final Rule for Payday, car Title, and Certain Installment Loans (CFPB 2015 – 0016). Reinvestment Partners supports a rule that is strong substantial underwriting of both earnings cost, defenses against financial obligation traps, and crucial protections to stop fraudulence.

Also, Reinvestment Partners arranged two sign-on letters, solicited by RP to non-profit teams that provide low-income customers.

Reinvestment Partners arranged this sign-on letter from people in diaper bank sites. A study of diaper bank customers in Missouri unearthed that one in five had utilized a loan that is payday. Evidence why these customers, whom otherwise re-use their diapers had been it maybe perhaps perhaps not when it comes to generosity of diaper banking institutions, talks to the importance of the CFPB’s rule-making.

Reinvestment Partners arranged this page, finalized by executive directors of nine new york non-profits plus one elected official, to guide a rule that is strong.

Our page into the FDIC addresses our issues because of the brand new high-cost installment loans made available from Republic Bank of Kentucky together with Elevate Credit. The page additionally addresses Republic’s Refund Advance item, brand new tax-related reimbursement loan.

Reinvestment Partners calls on our biggest banking institutions to maneuver far from making loans to businesses offering high-cost low-quality loans to consumers. In 2014, Reinvestment Partners published a study that revealed financing by banks to a number of high-cost customer boat finance companies. These loans help pay day loans, customer installment loans, pawn stores, buy-here car that is pay-here, and rent-to-own shops.

The report that is following changes considering that the book of Connecting the Dots: How Wall Street Brings Fringe Lending to Main Street back in December 2013:

Protection of our campaign:

Our page asking Wells Fargo to withdraw from their help of loan providers ended up being signed by a lot more than 30 customer teams from over 13 states.

In 2014, RP co-authored a written report with three partner companies on overdraft. Our research unveiled that lots of customers neglect to comprehend overdraft. Whenever we delivered testers to a number of branches, we unearthed that explanations regarding the solution varied.

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Reinvestment Partners is a 501()( that is c) nonprofit registered in the usa under EIN 31-1587628

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