AFSPA
ALTERNATIVE FINANCIAL SERVICE PROVIDERS ASSOCIATION
April 16, 2019

CFPB

ATTENTION:

TAKE ACTION

CFPB Notice of Proposed Rulemaking (NPRM) on "Payday, Vehicle Title, and Certain High-Cost Installment Loans"

Deadline to submit comments is May 15

In 2017, the CFPB issued a rule on on "Payday, Vehicle Title, and Certain High-Cost Installment Loans" that was needlessly complex and overbroad. It would have caused irreparable harm to industry businesses and eliminated an important form of credit to consumers.

Last month, the CFPB proposed a rule to rescind portions of the 2017 rule, including the Mandatory Underwriting Provisions. The Community Financial Services Association and others support this rule and are pleased the CFPB has taken steps to rescind the mandatory underwriting provisions of its 2017 Final Rule for small-dollar lending. Rescinding these requirements is warranted to avoid unnecessary industry burdens and harm to consumers. If the CFPB's 2017 Final Rule for small-dollar lending were to take effect, it would decimate the entire small-dollar lending industry. It is for these reasons, the CFPB should also delay the payment provisions of the 2017 Rule and begin a new rulemaking for payments.

TAKE ACTION! COMMENT ON THE PROPOSED REVISIONS!

Comments can be submitted now through May 15, and can be sent electronically, via email or through regular mail.
 
1) Submit electronically via at https://www.regulations.gov/document?D=CFPB-2019-0006-0001

2) Submit via email to 2019-NPRM-PaydayReconsideration@cfpb.gov
Include Docket No. CFPB-2019-0006 in the subject line of the message.

3) Submit via regular mail or hand deliver to: Comment Intake
Bureau of Consumer Financial Protection, 
1700 G Street, NW, 
Washington, DC 20552 
 Include Docket No. CFPB-2019-0006 in the letter. 
Must be mailed by Friday, May 10, to ensure arrival by deadline.

If you have questions or would like additional information, please email comment@cfsaa.com

CFSA


Repay
  Accept payments and fund loans anytime, anywhere with REPAY's intelligent and integrated payment technology.

ALABAMA: Bill to close AL payday loan loophole gains bipartisan support

MONTGOMERY, AL (WSFA) - Most consumers find their way to a short term lending agency through difficult circumstances. On Thursday, Alabama lawmakers rallied support for legislation that would give borrowers 30 days to repay the loan versus the current 10 to 14 day repayment schedule.

"In doing so, it lowers the APR in excess to 450 percent, down to a little over 200 percent," stated Sen. Arthur Orr.

The "30 Days to Pay" bill would specifically help those who fall into the debt cycle, forced to take out loan after loan to make the payments.

"This will impact 31 percent of the borrowers," stated Dr. Neil Bertie who serves on the Alabama Payday Advisory Committee. "These are the people that roll a loan over an average of 12 times. They can easily wind up paying 450 percent interest."

Alabama has the highest concentration of payday lending in the nation. The state's average annual percentage rate is 300 percent. The Alabama Banking Department shows residents pay more than $100 million in fees to out of state predatory lending companies every year.
Read more at WSFA.COM

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Introducing AI Lift, the AI-powered credit risk web service that leverages uncorrelated alternative data to identify the 20-30% of today's thin-file and no-file borrowers ready to be creditworthy customers.

INDIANA: Payday and subprime lending bill continues to divide

INDIANAPOLIS - Lawmakers in the Indiana House avoided all proposed changes to a bill to expand payday and subprime loan products as it was reviewed Thursday.

One day after Rep. Matt Lehman, R-Berne, advanced an amendment in the House Financial Institutions committee to adjust several provisions in Senate Bill 613, he again presented two new amendments when discussing the bill on the House floor.

The first would have prohibited lenders from renewing small or consecutive unsecured installment loans. A second proposal would have allowed lenders to apply pre-paid fees to more types of loan products.

But Rep. Woody Burton, R-Greenwood, who auth THE STATEHOUSEored legislation that helped to first introduce payday loan products across the state in 2004, opposed both amendments, voting against amendment two and speaking out against amendment three.

"That's just not something I can live with," Burton said.

Each of Lehman's amendments failed, with the chamber voting 40-52 and 39-53 respectively. Many Republicans joined Burton in voting no on each amendment.
Read more at THE STATEHOUSE FILE

microbilt
Alternative Credit Reporting

Shadow banking is a $52 trillion industry posing a big risk to the financial system

Nonbank lending, an industry that played a central role in the financial crisis, has been expanding rapidly and is still posing risks should credit conditions deteriorate.

Often called "shadow banking" - a term the industry does not embrace - these institutions helped fuel the crisis by providing lending to underqualified borrowers and by financing some of the exotic investment instruments that collapsed when subprime mortgages fell apart.

The companies face less regulation than traditional banks and thus have been associated with higher levels of risk.

In the years since the crisis, global shadow banks have seen their assets grow to $52 trillion, a 75% jump from the level in 2010, the year after the crisis ended. The asset level is through 2017, according to bond ratings agency DBRS, citing data from the Financial Stability Board.

The U.S. still makes up the biggest part of the sector with 29% or $15 trillion in assets, though its share of the global pie has fallen. China has seen particularly strong growth, with its $8 trillion in assets good for 16% of the total share. Read more at CNBC

MaxDecisions
Lending as a Service

Alchemy Is Redefining How FinTech Products Are Launched

Alchemy is an industry leading lending as a service organization that offers lending operating system, high end analytics and service to FinTech startups, socially financing companies and banks to launch new and innovative online products.

Alchemy's point of sale system is enabling a whole new class of FinTech enabled products to allow anyone to quickly launch their solution in the most cost effective way.

If you are an established bank that wants to offer new products and services to your existing clients, Alchemy can help you to launch your own personal installment loan, home improvement or medical financing products without having any involvement of your current IT infrastructure of staff.

If you are a FinTech startup that wants to focus on customer acquisition and customer experience. Alchemy and help you with all of your back office needs including launch and maintaining a state of the art Loan Origination System, Decision Engine and Loan Management System. Our clients don't have to write a single line of code or integrate with any third party services. Alchemy will design, launch your website or iOS app all the way to making sure payments are routined to and from your customers accurately.

Our vision is to redefine how FinTech products are launched. You no longer have to think about setting up a technology team, creating an analytics division or maintaining a fully compliant servicing team. Alchemy's full ranges of services can help you launch quickly.
Read more at ALCHEMY

Insight
We help you buy BETTER leads.

Approximately 12 million households use small-dollar loans each year

The average fee for a single payment small-dollar loan is $15 per $100 of the loan.

The monthly payment for an installment loan depends on the term of the loan.

96% of borrowers find small-dollar loans useful

Only 1.5% of all consumer complaints submitted to the CFPB concern small-dollar loans - far below other financial products like mortgages, credit cards, and student loans

CFPB complaints about small-dollar loans consistently fell for 22 straight months
CFSA
Alchemy
We are a revolutionary merchant service and technology firm servicing the debt repayment industry

John "Parker" Nealis joins MicroBilt as Senior Vice President of Sales

KENNESAW, Ga., April 3, 2019 /PRNewswire/ -- MicroBilt, a leader in risk management information for small and medium-sized businesses and leading provider of alternative consumer credit data is pleased to announce the appointment of Parker Nealis as MicroBilt's new Senior Vice President of Sales.

"Parker is a great fit for MicroBilt. In addition to his considerable experience in our core alternative lending markets, he brings a combination of operational savvy and entrepreneurial energy - both of which are well aligned with our corporate culture," said Walt Wojciechowski, CEO of MicroBilt.

Before joining MicroBilt, John was owner and operator at N&N International Consulting, a sales, marketing, and business process outsourcing consultancy specializing in the alternative lending and underwriting industries serving the consumer and business-to-business markets. During his tenure with N&N, he served in executive roles for several clients including interim positions as COO of Gateway Capital, Senior Operations and Sales Leader at Auction Credit Inc., and CMO for OTG. Read more at MICROBILT

  NDH
National Debt Holdings is a professional Receivables Management Company that partners with creditors to purchase and/or manage receivables at all stages of the account life cycle.

Pressure Mounts On CFPB Over Public Service Loan Forgiveness Program

Launched in 2008 as a provision of the College Cost Reduction and Access Act (CCRAA), the Public Service Loan Forgiveness program's objectives were pretty straightforward. The idea was to create a mechanism by which those who worked full-time in public service and made a good-faith effort at paying off their loans could discharge those loans after a certain fixed period. Supporters of the PSLF argued that that education is increasingly an expensive burden - and the historically low pay associated with public service work could keep interested but indebted students away from work that needs doing. Creating a financial incentive could help push more of those students into public service work.

As it turned out, that simple concept ended up being more complicated in implementation than initially planned. It took a few years after rollout for the government to solidify an official form borrowers could use to make sure their work qualified as public service. And some of the requirements for having a balance forgiven became well known - 120 monthly payments (10 years), while working full-time for a qualified employer. But others things - like the fact that it has to be a "qualifying plan" or that borrowers need to consolidate their loans to qualify or that consolidating resets the PSLF payment clock back to zero - those things were not as well understood.

Well, at least at not until recently anyway. Because lots of borrowers who went on to work in public service are now reaching the 120 payments mark - and applying to have their loans forgiven. And they are being denied. According to the Education Department, as of September of last year more than 41,000 borrowers had requested forgiveness, but just 206 had had their loans discharged.
Read more at PYMNTS.COM

Merchant Boost Announces Name Change to ValidiFI
ValidiFI
Redefining how financial service businesses measure risk and process payments.

'All options' on the table for cracking down on Wells Fargo - CFPB

Wells Fargo may be headed for yet more regulatory trouble, with the Consumer Financial Protection Bureau telling Cong

The scandal-plagued bank is operating under consent orders that require it to remediate customers harmed by its wrongdoing and institute reforms. Recently, Sen. Elizabeth Warren (D-Mass.) and Sen. Sherrod Brown (D-Ohio) sent inquiries to several regulators asking about Wells Fargo's progress in satisfying the orders.

In a letter responding to the senators, CFPB Director Kathy Kraninger said the bank wasn't doing enough to fulfill its obligations.

"I can tell you that while the Bureau is working with Wells Fargo to ensure its compliance with the consent order, I am not satisfied with the Bank's progress to date and have instructed staff to take all appropriate actions to ensure the Bank complies with the consent order and Federal consumer financial law," Kraninger wrote. "Broadly speaking, I consider all options on the table for enforcing Bureau consent orders."

Federal Reserve Chairman Jerome Powell also expressed dissatisfaction with the bank's efforts to reform its policies. Last year, the Fed imposed an asset cap on Wells Fargo in order to force the bank to address its problems - a cap that is still in place.
Read more at MORTGAGE PROFESSIONAL AMERICA

Payliance
Payliance: Powerful Payment Processing Technology

As cashless stores grow, so does the backlash

NEW YORK (AP) - Hembert Figueroa just wanted a taco.

So he was surprised to learn the dollar bills in his pocket were no good at Dos Toros Taqueria in Manhattan, one of a small but growing number of establishments across the U.S. where customers can only pay by card or smartphone.

Cash-free stores are generating a backlash among some activists and liberal-leaning policymakers who say the practice discriminates against people like Figueroa, who either lack bank accounts or rely on cash for many transactions.

Figueroa, an ironworker, had to stand to the side, holding his taco, until a sympathetic cashier helped him find another customer willing to pay for his meal with a card in exchange for cash.

"I had money and I couldn't pay," he said.

The issue got some high-profile attention this week when retail giant Amazon bowed to pressure from activists and agreed to accept cash at more than 30 cashless stores, including its Amazon Go convenience stores, which have no cashiers, and its book shops. Amazon declined to say when the change would happen.   Read more at KXNET.COM

Dreher Tomkies LLP
Dreher Tomkies LLP is a law firm concentrating in the areas of Banking and Financial Services law.

Military personnel caught in crossfire over lending law

The first major standoff between Democratic lawmakers and the Trump-appointed director of the Consumer Financial Protection Bureau is threatening to put military servicemembers at risk.

CFPB Director Kathy Kraninger and her congressional critics are clashing over a law meant to protect military personnel from predatory lenders, who can charge interest rates of as much as 400 percent. Kraninger says the bureau lacks the power to monitor violations of the statute - even though the CFPB did just that during the Obama administration - while Democrats insist that it can.

Neither side is budging. Kraninger says she wants legislation to explicitly grant the bureau more authority over the law, which caps most loans to servicemembers at 36 percent. Democrats are resisting, fearing that reopening the Military Lending Act would merely lead to new loopholes.

This is a fight the Republicans don't want. They are unwilling to criticize the Trump administration's stance but at the same time are fearful of appearing indifferent to the plight of servicemembers, who are particularly vulnerable to abuses by such lenders.

The top Republicans on the committees with oversight of the CFPB and on the Armed Services panels declined to comment for this story. Read more at POLITICO

Trust Science
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Business Intelligence: What can we tell you about your customers - and your business - that you don't know? by Kristen Hoyman

Business intelligence (BI) seems to be the hottest new buzzword in town and can be found across a multitude of industries and platforms. For those who don't understand it, or perhaps for those who haven't had the chance to fully realize its purpose and impacts, it can be vague and often intimidating. Upon hearing the term, you may imagine a robot spitting out data or an unending sequence of unreadable formula tables and statistical jargon. These preconceived notions may not be entirely misplaced, but the true beauty of BI lies in the analytical simplicity of its end results.

BI refers to the technologies, tools, infrastructures, and applications that are used to collect, store and analyze complex data sets to support better, more informed decision making. The ultimate outcome of BI is to package the data into easily understandable results to provide insight into business best practices and trends.
But how does one start using BI to take advantage of all it can offer? The capabilities of BI are endless and can often be overwhelming with no clear start or finish line; in fact, the entire course can seem hazy and insurmountable at times. That's why Susan Perlmutter, Chief Revenue Officer of REPAY, recommends business leaders partner with a trusted vendor who is already collecting important data points about their businesses and customers during normal, day-to-day operations.

"It's best to find a partner who can not only collect the data on your behalf, but who can also analyze and package that data into digestible, easy to understand pieces of information that can translate into best practices, trends, and action items for your business," says Perlmutter. She is surely no stranger to the advantages of BI as REPAY continues to build robust business intelligence services for its clients. Read more at REPAY

TransUnion
Compete in the data-driven lending era

Employees' money worries drain employers' bottom line

Many employees are still struggling financially, even though the economy is better and unemployment is down. How bad is it? Statistics show that 80% of U.S. workers are living paycheck-to-paycheck. That causes their own financial stress and creates a problem for employers as well.

Whether it's student loans, car payments, mortgage/rent payments, credit card debt, an unexpected expense or some other financial matter that they are worried about, employees are spending time at work on these issues rather than concentrating on the job they are being paid to do.

In fact, 43 percent of employees distracted by their finances at work spend three or more hours each week in the office thinking about or dealing with their personal financial issues, according to PwC's 2018 Employee Financial Wellness Survey. Add that up. That's 150 hours of lost productivity per year per employee who is sidetracked from doing their work because of financial stress.
Read more at CHICAGO BUSINESS JOURNAL

LoanPaymentPro
We are a revolutionary merchant service and technology firm servicing the debt repayment industry.
AFSPA
ALTERNATIVE FINANCIAL SERVICE PROVIDERS ASSOCIATION

Alternative Financial Service Providers Association
757.737.4088

315 Tuscarora St., Lewiston, NY 14092
dan@afspassociation.com
www.afspassociation.com