Earlier quoted context omitted.
> If you take away that option, I don’t get my car fixed and lose my job. That’s the alternative. Except the rule that is being killed is the one that told lenders they needed to check to ensure that the borrower would be able to pay the loan back. In your case, with your car and your job, you would pass this test. And if you couldn’t then lending the money would put you in a worse position than immediate unemploymen…
> And if you couldn’t then lending the money would put you in a worse position than immediate unemployment I’m glad some upper middle class attorney or policy wonk at CFPB gets to make the decision that it’s better for me to lose my job than to deal with debt I can’t repay!
Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
281–290 of 305 posts
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#282Earlier quoted context omitted.
> So then they decide to: Ban the bad thing people do for relief when they are desperate. All while not ameliorating the suffering that cause the desperate bad relief efforts. There's another option, of course: create regulations to limit only the harmful effects of the thing. It's not like there's some law of economics that says we can't find a way to make loans accessible to people who need money without also enabl…
Except... we have regulations. It's state by state. Meaning, the laws adapt to the needs of the people of each state. The new laws would have removed 90% of the industry, including my ability to have participated. I fully supported the limitation of debiting end user accounts, which was part of the legislation. I'm completely against the need to 'verify someone can pay'... which I read as basically requiring credit s…
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#283Earlier quoted context omitted.
Payday loans are some of the things that the unbanked turn to . Using a payday loan shark does not make one banked.
Payday loans structurally require you to be banked. The offering is "I will advance you $400 in cash today for a $415 check dated in a week. You can come back and buy your check back for $415. If you do not, I will deposit it." The security here _is the check drawn on your checking account_; without that the payday loan has markedly higher collection costs and markedly lower probability of collection. Also, they use…
When I took out a payday loan they made me sign a PAD authorization (pre-authorized debit) that was timed to hit my account the same day as my next payroll.
They also needed my last bank statement so they could 1.) verify my payroll was through direct deposit, and 2.) help them estimate the right date for their PAD.
In other words: yup! You must be banked!
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#284Earlier quoted context omitted.
> Which consumers is the CPB protecting? (1) It's the CFPB (Consumer Financial Protection Bureau), the headline provided a description not a name (titlecase makes this ambiguous, though the body provides the correct name.) (2) It's not protecting anyone; the administration is hostile the CFPB mission. It is being neutralized from within.
I read through about half the CFPB rulemaking analysis that's being reported here and while I agree that the Trump administration is hostile to the CFPB, I don't think this is a fair summary of what's happening with the payday loan rules. As I understand it, the Obama-era CFPB rules for short-term loans basically decimate payday lending. For instance: most payday loans (85+%) are repaid, but most also require multipl…
That's the basic argument in a particular branch Republican thought, against the entire system of regulatory power delegated by congress to federal regulatory agencies. It seems weird to state it unlabeled.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#285Earlier quoted context omitted.
I read through about half the CFPB rulemaking analysis that's being reported here and while I agree that the Trump administration is hostile to the CFPB, I don't think this is a fair summary of what's happening with the payday loan rules. As I understand it, the Obama-era CFPB rules for short-term loans basically decimate payday lending. For instance: most payday loans (85+%) are repaid, but most also require multipl…
So the basic argument boils down to That's the basic argument in a particular branch Republican thought, against the entire system of regulatory power delegated by congress to federal regulatory agencies. It seems weird to state it unlabeled.
There's also a broad partisan split on the question of how much new authority the CFPB actually has for regulating non-banks. One view of the CFPB is that its regulatory authority (as opposed to its supervisory authority, which is expansive) is derived primarily from the previous agencies it consolidates, none of whom had a charter to end payday lending. So another way to look at this is, it's within CFPB's charter to use its authority to collect data unfavorable to payday lenders and then write a report about how terrible payday lending is, but it remained up to Congress to rely on that report to impose a federal ban on the practice.
The overarching point is that this isn't so much a distinct feature of Trumpian corruption, so much as simply a predictable consequence of Republicans controlling the executive branch.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#286Earlier quoted context omitted.
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…
Forgive me for lol'ing, but the LAST thing i'd want to see is payroll done like most software places do version control. I've tried to teach teams of analysts version control, the xkcd panel is a documentary, not a joke. https://xkcd.com/1597/ Also, its 'totally possible' only in the sense that it really isn't: i.e. if like many tech people you ignore actual social, infrastructure, law and cultural issues and start b…
And I did mean "totally possible" in the sense you indicate, that is, technically possible, but far from a solved solution (after all, I'm not quitting my day job to start offering this as a service). The historical reason for a payday is that cash is hard to move, so the armored car would swing by and people would line up for money; later banks would do the same thing. Because "paydays" and "paystubs" exist, other processes and organizations latched on to them as a standard place to add more process, so "running payroll" became a more and more complicated beast, thus making it even harder to make it an incremental process.
So the first barrier is now gone -- while some segments of the population are cash-heavy, modern inter-bank transfers and the rise of electronic payment systems mean that banks can easily handle the cash outlays necessary to support the demand for physical specie out of cash on hand (not to mention improvements in modeling that allow them to anticipate cash demand).
But the rest of the "hanger-ons" are not even close to being able to support this; everything from landlords asking for paystubs, to how payroll taxes are handled, to the way that benefits (like health insurance or retirement plans) are calculated, to the way that non-direct-payroll services like phone bills and cable bills are calculated, and the idea of limits on services (data, etc.) that are metered on a sliding monthly window instead of a continuous rolling window mean that it would be very difficult to do effective planning, unless all services started adopting these methods.
To actually allow people to do this you'd almost need to have intermediate services -- a "cell phone account" that gets funded, say, daily, and remits payments to the cell phone provider on a monthly basis. Similarly a "rent account", and so on, that would gradually allow you to get an idea of what your actual cash flow looks like, without having to deal with periodic shocks that represent lump outlays and receipts.
For now it's just an interesting thought that the foundation that the concept of "payday" is build on has turned to sand, and the question is whether we can find a way to take advantage of this new flexibility. Yudkowsky's tweet addresses one possible way that this may provide a benefit, and it's interesting food for thought even though I'm not completely convinced.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#287Earlier quoted context omitted.
So the basic argument boils down to That's the basic argument in a particular branch Republican thought, against the entire system of regulatory power delegated by congress to federal regulatory agencies. It seems weird to state it unlabeled.
I'm more sympathetic to the Democratic side of the argument then the Republican argument, but the notion that major changes to policy should be made through legislation and not administrative rulemaking isn't really a fringe idea; it is as least practically universal to Republicans, not a particular branch of them. There's also a broad partisan split on the question of how much new authority the CFPB actually has for…
It's not a fringe idea in itself but in the context it's a talking/advocacy point that is a foundational building block of something quite different. I wish I knew more about spotted owl or food labeling matters so I don't have to use such overwrought examples so excuse/bear with me:
'states rights' is in itself not a fringe idea but at the time it was deployed entirely to advocate against federal civil and voting rights legislation - that was the goal, rather than a desire to debate the nature of the federal structure of the United States. 'Patient safety' is similarly deployed with the goal of restricting reproductive rights.
'Congress should spell it out' is precisely in that vein - its goal is the structural defanging of the federal regulatory regime. To my mind, that's a fairly conventional, mainstream analysis rather than than some lefty fever dream of mine. In this particular case especially - I think (if I'm remembering this right) both houses of Congress took the matter under consideration and neither brought it to a vote.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#288Earlier quoted context omitted.
I'm more sympathetic to the Democratic side of the argument then the Republican argument, but the notion that major changes to policy should be made through legislation and not administrative rulemaking isn't really a fringe idea; it is as least practically universal to Republicans, not a particular branch of them. There's also a broad partisan split on the question of how much new authority the CFPB actually has for…
isn't really a fringe idea It's not a fringe idea in itself but in the context it's a talking/advocacy point that is a foundational building block of something quite different. I wish I knew more about spotted owl or food labeling matters so I don't have to use such overwrought examples so excuse/bear with me: 'states rights' is in itself not a fringe idea but at the time it was deployed entirely to advocate against…
More important to me, though, is that CFPB is essentially the DHS of finance (a Voltron agency that centralizes a bunch of random oversight authorities that already existed) and neither the CFPB's enacting legislation (in Dodd-Frank) nor any of the extent authorities CFPB draws on appear to give it the authority to effectively end payday lending.
I think it's fair game for the party that (1) controls the CFPB now and (2) was already and (often) in good faith opposed to regulatory-state-creep and (3) definitely opposed to the idea of a nationwide ban on payday lending given that this issue is already aggressively litigated in the states to then say "the previous CFPB was really reaching when they tried to quietly eradicate most payday lending, and now that we've taken over, we're not going to push the ball to the end zone on that attempt".
To me: a good reason not to vote for Republicans! But not a good example of how this administration is breaking norms or rules. And there are so many real examples of that!
I'm only really irritated by the argument that this policy change was brought about by payday lending lobbyists, as if mainstream Republican thought didn't already say "consumers should have the freedom to purchase financial services they think they need". It's not even hard to make that argument colorable: you have terrible credit, live paycheck-to-paycheck (like most Americans), have an unexpected expense, pay it, and a week later find out you're going to have your electricity turned off. Without payday loans, a lot of Americans in this (common) scenario are S.O.L. This is what Rayiner was saying when he said the old CFPB attempt was addressing the symptoms and not the problem.
I don't fully agree with this argument! But I can't easily shoot it down.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#289Earlier quoted context omitted.
"Fentanyl has a market" Are you saying that a cancer patient ought not to use Fentanyl when Oxycontin no longer is enough and go directly to morphine? This is not obviously a "poor choice" from my perspective.
No. How would you even come to that conclusion? They are clearly talking about the black market for the drug.
The parent comment had a parallel construction where the drug was the odd one out, having legitimate value in some contexts. One implication of that might be that the commenter was unaware of the legitimate value, because if they were aware, they could have avoided the unsatisfactory parallel.
Re: Consumer Protection Bureau Aims to Roll Back Rules for Payday Lending
#290Earlier quoted context omitted.
isn't really a fringe idea It's not a fringe idea in itself but in the context it's a talking/advocacy point that is a foundational building block of something quite different. I wish I knew more about spotted owl or food labeling matters so I don't have to use such overwrought examples so excuse/bear with me: 'states rights' is in itself not a fringe idea but at the time it was deployed entirely to advocate against…
I don't think your argument is a lefty fever dream, I just think there's a mainstream good-faith argument that rebuts it. More important to me, though, is that CFPB is essentially the DHS of finance (a Voltron agency that centralizes a bunch of random oversight authorities that already existed) and neither the CFPB's enacting legislation (in Dodd-Frank) nor any of the extent authorities CFPB draws on appear to give i…
I don't think the specifics are some glaring example of trumpian norm-breaking or corruption or whatnot, either.