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Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

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Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#21
post #18

This decision really comes down to are people better off if:(1) they have access to loans even if they are high fee or (2) they are better off if they can’t get the loans at all?

Why are those the only two options? Is there a shortage of wealth in the USA?

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#22

Isn't the problem less about predatory payday loans and more an existential issue around the fact that so many people can't afford to simply live ? People take these bad loans because they literally have no other choice. They are using these loans to buy groceries and cover bills, not splurge on non-essentials.

I saw a tweet [1] that followed a thread on the concept that paydays are not really a requirement any more -- it is totally possible with our existing banking infrastructure to pay salaries on a more continuous basis, but we've built up a huge amount of institutional momentum around the idea that running payroll is a complex and laborious process that we want to infrequently.

By parallel in software engineering, branch merges/integrations used to be very expensive (in cvs/subversion/perforce) and thus were done rarely, and were more expensive and difficult because changes had more time to accumulate, but with DVCSs the problem is flipped on it's head and now we merge branches routinely without fear. We need to fix payroll so that running it on a nearly continuous basis is possible.

[1] https://twitter.com/ESYudkowsky/status/1093187875166797824

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#24
post #2

Big benefit for payday lending companies who charge obscene fees mostly in poor and minority areas of the country. Which consumers is the CPB protecting?

Arguably, the consumers that the CPB is protecting is those who are aware of the fees and conditions but still require payday loans, who would be excluded from consideration by the new rules [1], which do not change the interest rate requirements but exclude some customers from eligibility. If people didn't want these loans, the companies would not exist. If the loans were capable of being serviced at a lower rate, t…

You can also look at it from another angle, which is that companies can and will ruthlessly exploit people without other options or choices, followed by hiding fees, clauses etc designed to keep people coming back.

I don't think this is a problem of regulation run amuck at all. It reminds me a lot of how games whose primary focus is gambling can and do extensively reach out to children in order to either earn money through advertising or by making kids into gambling consumers.

Consumers may demand it, but you have to look at what companies do to increase demand and keep repeat customers. You could argue that if people didn't want to play those games they wouldn't exist; I argue that companies create consumers through malicious policies and advertising.

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#25

Isn't the problem less about predatory payday loans and more an existential issue around the fact that so many people can't afford to simply live ? People take these bad loans because they literally have no other choice. They are using these loans to buy groceries and cover bills, not splurge on non-essentials.

I saw a tweet [1] that followed a thread on the concept that paydays are not really a requirement any more -- it is totally possible with our existing banking infrastructure to pay salaries on a more continuous basis, but we've built up a huge amount of institutional momentum around the idea that running payroll is a complex and laborious process that we want to infrequently. By parallel in software engineering, bran…

Right - there are startups that are doing this i.e. https://www.crunchbase.com/organization/activehours has raised $190m and in the top 20 finance apps in the app store.

I assume these customers have less a need to take out a payday loan, but it could also be the case that expenses > pay regardless of when you receive income throughout the month.

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#26

Isn't the problem less about predatory payday loans and more an existential issue around the fact that so many people can't afford to simply live ? People take these bad loans because they literally have no other choice. They are using these loans to buy groceries and cover bills, not splurge on non-essentials.

I saw a tweet [1] that followed a thread on the concept that paydays are not really a requirement any more -- it is totally possible with our existing banking infrastructure to pay salaries on a more continuous basis, but we've built up a huge amount of institutional momentum around the idea that running payroll is a complex and laborious process that we want to infrequently. By parallel in software engineering, bran…

If I were paying a bunch of employees, I'd like to hold onto the money for a couple weeks before paying it out if only to mooch off of the small bank interest.

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#27

I'm of the mind that many of these lenders are indeed predatory, but prohibiting loans to high-risk borrowers at realistic rates (based on the risk) just leaves them unbanked rather than poorly-banked.

Payday loans are some of the things that the unbanked turn to. Using a payday loan shark does not make one banked.

Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending

#28

I'm of the mind that many of these lenders are indeed predatory, but prohibiting loans to high-risk borrowers at realistic rates (based on the risk) just leaves them unbanked rather than poorly-banked.

If you read the article, there's a little more nuänce than that. One thing listed right up front is a limit on how many times a lender can try to withdraw funds from your account.

If they have, say, a $200 NSF charge, and your payment bounces, they can try every business day, racking up $1,000 a week in NSF fees.

Companies that do this kind of thing aren't trying to collect their original payments in good faith, they're trying to suck every last droplet of blood from those lenders who have a temporary problem but then get some money.

Limiting attempts to two would stop that.

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