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Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

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Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#11
post #3

I'm generally not a fan of regulation. But lately, I've been changing my opinion on that. I don't see how we can all play in the economy game without having a set of unambiguous rules and referees to enforce them. Regulations do add overhead, sure, but how else can we prevent companies from acting in ways that are detrimental to society? Capital finds the shortest path to profits, and without rules, it becomes a quic…

There ain't no such thing as a free lunch.

Sure you'd love to make 20% returns, and so would literally every person who has cash. If there were a pool of people willing to pay 20% interest without the risk of default or non-payment, then everyone would be out there lending to them, and the market would saturate, and someone would say "hey, I could get more customers with 19% interest", and so on, until you basically can't charge more interest than nominal market rates for interest. That's the "race to the bottom" of capitalism, not the increased number of shady tricks that you would pay to get the 20% return.

The reality is somewhat different from two axes. One is the regulatory axis; you can't just up and start making payday loans; there are huge regulatory burdens that come with it that exist as a moat to keep out new players in the market by increasing the cost of compliance.

The other is more direct and unrelated to regulation; the 20% is not realistic -- non-payment and default do exist, and you have to collect in order to avoid making huge losses, so with the total costs involved, the actual rate of return on this class of loans ends up being not much better than free-market interest rates anyway; you can get additional returns by improving quality of service or offering better features, or reducing the cost of collections, or, in this case, using the ability to charge fees to try to recoup some of that loss.

So what you end up with is a system where the problems inherent in #2; subprime lending is risky and encourages taking advantage of customers, which leads to regulation, which makes things worse by limiting the competition, and eventually leads to a spiral where we keep thinking that we can solve the problems caused by the previous regulation with more regulation. And eventually someone breaks out of the cycle by offering the same product but just slightly different enough to not be covered by the regulations; they take over the market and then everyone copies them, and then we start the regulation game again.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#12
Adding regulation without forbidding payday loans sounds to me like the worst thing you can do. In emergency situations, it can be perfectly rational to take out such a loan, despite high interests and fees. On the other hand, if you take a payday loan for an unneeded expenditure, you will have even less money in the long term. So either you get rid of the regulation, in order to lower the fees. Or you forbid payday loans outright, to prevent people from hurting themselves (while ignoring the needs of those who are in an emergency situation). I don't think there is any real middle ground. Everybody loses when you do something that increases fees without actually helping those who are affected by this.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#13
post #4

There's demand for these sorts of loans, so if you outlaw them the demand doesn't go away - it moves to the blackmarket. The classic "loan shark", or local guy with cash that will have his goon break your legs if you don't pay it back. That's fine, we can outlaw and drive it underground, just as we tried with alcohol, and just as we do now with various drugs. Sometimes society would rather pretend demand for some pro…

There are far less exploitative options out there for providing this service though. See emerging fintech offerings like: https://www.earnin.com/ , https://www.dave.com/ . There is also a concept called earned wage access that helps solve this issue and there are a few emerging players in that space as well. "The invisible hand" isn't perfect and sometimes regulation helps push people towards better options. We don't…

> earned wage access

Sounds like debt bondage.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#14
post #12

Adding regulation without forbidding payday loans sounds to me like the worst thing you can do. In emergency situations, it can be perfectly rational to take out such a loan, despite high interests and fees. On the other hand, if you take a payday loan for an unneeded expenditure, you will have even less money in the long term. So either you get rid of the regulation, in order to lower the fees. Or you forbid payday…

Why would removing regulation reduce fees, and why would adding regulation increase them?

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#15
post #3

I'm generally not a fan of regulation. But lately, I've been changing my opinion on that. I don't see how we can all play in the economy game without having a set of unambiguous rules and referees to enforce them. Regulations do add overhead, sure, but how else can we prevent companies from acting in ways that are detrimental to society? Capital finds the shortest path to profits, and without rules, it becomes a quic…

What do you think about the idea that if someone is charging 20% on a loan and making easy money, you can offer the same service for 15% and take their business?* That is a race to the bottom, but it seems like it would be good for the customer. * This is essentially what credit unions do with signature loans.

Can you really? Do payday loan customers typically comparison shop?

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#16
post #3

I'm generally not a fan of regulation. But lately, I've been changing my opinion on that. I don't see how we can all play in the economy game without having a set of unambiguous rules and referees to enforce them. Regulations do add overhead, sure, but how else can we prevent companies from acting in ways that are detrimental to society? Capital finds the shortest path to profits, and without rules, it becomes a quic…

What do you think about the idea that if someone is charging 20% on a loan and making easy money, you can offer the same service for 15% and take their business?* That is a race to the bottom, but it seems like it would be good for the customer. * This is essentially what credit unions do with signature loans.

If the 'invisible hand of the market' was indeed working, why are such obscene rates common?

In my mind it's profiteering on the backs of impoverished people.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#17
post #15

Earlier quoted context omitted.

What do you think about the idea that if someone is charging 20% on a loan and making easy money, you can offer the same service for 15% and take their business?* That is a race to the bottom, but it seems like it would be good for the customer. * This is essentially what credit unions do with signature loans.

Can you really? Do payday loan customers typically comparison shop?

To further reinforce this point, find me a payday lender that up-front lists their Annual Percentage Rate.

They really don't which makes comparisons impossible or very hard work.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#18
post #3

I'm generally not a fan of regulation. But lately, I've been changing my opinion on that. I don't see how we can all play in the economy game without having a set of unambiguous rules and referees to enforce them. Regulations do add overhead, sure, but how else can we prevent companies from acting in ways that are detrimental to society? Capital finds the shortest path to profits, and without rules, it becomes a quic…

I heard an interesting quote lately about how federal aviation regulations were "written in blood". That nobody really wanted the regulations but time after time common sense and commercial interests failed to provide a safe operating environment.

I've been thinking about that a lot: while there are certainly some over-regulated industries, when you dig into the "why" on any particular rule you usually find some horror story.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#19

Earlier quoted context omitted.

There are far less exploitative options out there for providing this service though. See emerging fintech offerings like: https://www.earnin.com/ , https://www.dave.com/ . There is also a concept called earned wage access that helps solve this issue and there are a few emerging players in that space as well. "The invisible hand" isn't perfect and sometimes regulation helps push people towards better options. We don't…

> earned wage access Sounds like debt bondage.

The way it actually works is that people get payed before their paycheck if they need it at zero interest. When executed correctly there is no debt the money they took is just deducted from their paycheck.

This is how payday advances worked for most people before the age of complex payroll systems. You used to be able to ask your boss to get payed early for the time you had already worked. Now that is really hard because "the system isn't set up like that"

You can find out more by googling it.

Payday loans are much more akin to debt bondage, in that they are _often_ the start of a debt cycle that is extremely difficult to break.

Re: Move to Pull Consumer Protection Rule Heightens Debate over Payday Lending

#20

Earlier quoted context omitted.

What do you think about the idea that if someone is charging 20% on a loan and making easy money, you can offer the same service for 15% and take their business?* That is a race to the bottom, but it seems like it would be good for the customer. * This is essentially what credit unions do with signature loans.

If the 'invisible hand of the market' was indeed working, why are such obscene rates common? In my mind it's profiteering on the backs of impoverished people.

What makes you think the rates are obscene?
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