Small dollar lending : how triple-digit annual percentage rates became the norm & how institutions can promote more affordable options
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Census data show that about 60 million, mostly low-income and minority, American adults either do not have a bank account or have an account but also rely on non-bank financial products to make ends meet. These products, such as payday loans, often have high costs per dollar lent and have historically fallen into gaps in both state and federal regulation. Texas, home of the largest payday lending companies in the country and over 2,500 payday lenders, provides an instructive case study of how small-dollar loan regulation has developed over the years, how non-bank financial institutions navigate the law, and how some organizations with non-profit missions have sought to offer affordable loan alternatives. This paper places current lending regulation in historical context, surveys federal and Texas law related to small-dollar loans prior to and following the financial crisis in 2008, and provides highlights from a federal pilot program designed to encourage banks to offer affordable small-dollar loan products. It also examines the experience of a community development financial institution (CDFI) in Brownsville, Texas that launched a small-dollar loan program in 2012. The federal pilot and Brownsville cases provide insights regarding the viability of affordable small-dollar products, as well as the challenges facing non-profit-maximizing institutions such as CDFIs when trying to develop loan programs under the current regulatory regime. Ultimately this paper concludes that, while there may always be a market for high-cost non-bank financial services, a combination of federal efforts to promote affordable options at banks and efforts by community-oriented CDFIs can go a long way towards providing lower-cost alternatives for people who currently rely on high-cost, non-bank products.