AFSPA
ALTERNATIVE FINANCIAL SERVICE PROVIDERS ASSOCIATION
May 2, 2019
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Republicans and Democrats cite the same Federal Reserve data in high-stakes debate on payday lenders

The public has until May 15 to comment on a CFPB proposal to roll back Obama-era restrictions on payday loans

Payday lenders are once again under the microscope this on Capitol Hill. Republican and Democratic lawmakers are using the same U.S. Federal Reserve data to make their cases.

The Consumer Financial Protection Bureau wants to reconsider an Obama-era rule designed to keep payday lenders from preying on vulnerable consumers. The Obama-era rule - implemented under former CFPB director Richard Cordray in 2017 - set stricter conditions for short-term loan companies, requiring them to assess the creditworthiness of the borrowers.

The government agency has said it wants to reverse course because, it argues, the rules have choked off access to credit for people who need it most. Republican lawmakers want to ease some of the restrictions on these lenders that Democrats say have punitive, and sometimes astronomical, interest rates.

Rep. Gregory Meeks, a Democrat from New York, said it was "deeply disappointing" by the CFPB's move to rescind the Obama-era rule. He chairs the Subcommittee on Consumer Protection and Financial Institutions within the Committee on Financial Services. "It is hard to see how the actions of the bureau under Mr. Trump's leadership team is fulfilling its core mission of putting consumers first," he said.   Read more at MARKETWATCH 

CFPB

ATTENTION:
Deadline to submit comments is May 15

TAKE ACTION

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

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
CFSA

CFSA Submits Statement For The Record on HOUSE FINANCIAL SERVICES COMMITTEE HEARING

United States House of Representatives
Financial Services Committee Subcommittee on Consumer Protection and Financial Institutions  Hearing on "Ending Debt Traps in the Payday and Small Dollar Credit Industry"
April 30, 2019

Chairman Meeks, Ranking Member Luetkemeyer and members of the Subcommittee, thank you for the opportunity to submit a statement for the record for today's hearing on the small-dollar, short-term credit industry. My organization, the Community Financial Services Association of America (CFSA), is the leading  national association representing regulated, non-bank, small-dollar lenders, and we appreciate the chance to provide our views.

We take issue with the title of the hearing, as it presupposes small-dollar loans are, in fact, debt traps and that such a characteristic is unique only to this type of credit. We would challenge the subcommittee to consider what type of credit is not a debt trap. The Schumer Box on a consumer credit card statement with a $9,000.00 balance discloses a payoff period of 25 years if only the minimum monthly payment is made. I would submit to you that is indeed a debt trap.

There is a larger problem with consumer credit in this country, and it doesn't start with small-dollar loans. This industry is an easy target because of common misperceptions, blatant mischaracterizations by our critics and patronizing dialogue from those who believe they are better equipped to make decisions about how and when certain consumers access credit. This patronizing dialogue asserts that consumers of smalldollar loans are predominantly low-income, minorities who are "financially unsophisticated" and aredesperately in need of protection by the government. This is simply not true. Read more at CFSA

Payliance
Payliance: Powerful Payment Processing Technology

Democrats aim to roll back Mulvaney's 'anti-consumer' measures at nation's watchdog agency

The bill includes provisions that would require the Consumer Financial Protection Bureau's consumer complaint database to remain public, and would end the director's ability to limit the legal reach of its fair lending office.

It also would establish an Office of Students and Young Consumers to focus on financial education among the nation's youth. While the bill might be passed if brought to floor vote in the House, it would likely go nowhere in the Senate.

A bill that would reverse some controversial moves made at the nation's consumer watchdog could get a floor vote in the House in May, according to a letter that Democratic lawmakers received from their leadership late last week.

The Consumers First Act, which was approved 34-26 by the House Financial Services Committee in late March, would require the Consumer Financial Protection Bureau to "promptly reverse all anti-consumer actions" made under its previous acting director, Mick Mulvaney, who is now President Trump's acting chief of staff. The letter from Majority Leader Steny Hoyer, D-Maryland, said the measure is one of many that the House may vote on next month.
Read more at CNBC

Accelitas
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.

10% of Americans don't use the internet. Who are they?

For many Americans, going online is an important way to connect with friends and family, shop, get news and search for information. Yet today, 10% of U.S. adults do not use the internet, according to a new Pew Research Center analysis of survey data.

The size of this group has changed little over the past four years, despite ongoing government and social service programs to encourage internet adoption in underserved areas. But that 10% figure is substantially lower than in 2000, when the Center first began to study the social impact of technology. That year, nearly half (48%) of American adults did not use the internet.

Internet non-adoption is linked to a number of demographic variables, including age, educational attainment, household income and community type, the Center's latest analysis finds.

For instance, seniors are much more likely than younger adults to say they never go online. Although the share of non-internet users ages 65 and older has decreased by 7 percentage points since 2018, 27% still do not use the internet, compared with fewer than 10% of adults under the age of 65. Household income and education are also indicators of a person's likelihood to be offline.
Read more at Pew Research Center

LoanPaymentPro
We are a revolutionary merchant service and technology firm servicing the debt repayment industry.

Teen credit card use is up. Here's why

More and more children under the age of 14 have their own credit card Opens a New Window. to use at their leisure, according to a new report.

Since 2012, credit card-carrying-teens have increased more than four times to 17 percent among 8-to-14-year-olds, up from just 4 percent seven years ago, according to data from investment management firm T. Rowe Price.

Moreover, 21 percent of the 1,500 parents polled in a recent survey Opens a New Window. by Creditcard.com found that some kids without their own card are still using their parents without their permission.

Of those polled, six million American parents say they have knowingly given a credit card to their child.

Ted Rossman, an analyst for CreditCard.com told FOX Business that he thinks the increase is positive with the exception of those teens using it deceptively.
Read more at FOX BUSINESS

MaxDecisions
Lending as a Service

Restricting Access to Small Loans Amounts to Legalized Redlining

A rule finalized by the Consumer Financial Protection Bureau in 2017 to impose onerous regulations on small-dollar loans would dramatically reduce access to credit for many struggling Americans who are locked out of the traditional banking system because of credit or low income.

It's worth asking, to what extent do restrictions on small-dollar loans, including payday loans, work to legalize redlining and discriminate against the most vulnerable groups of Americans?

For more than a century, allegations of redlining - the practice of using geography to screen customers and deny loans to low-income neighborhoods, people of color, and those living in high-crime areas - have dogged U.S. financial institutions. As recently as 2015, the CFPB took action against a bank over allegations of redlining. Yet, ironically, the CFPB's crackdown on small-dollar loans would have similar effects.

With 40 percent of American adults unable to cover an unexpected $400 expense, the government should be taking steps to expand access to credit for low-income households, not reduce it. Ten million Americans rely on payday loans every year, not to mention single-payment vehicle title loans and longer-term balloon payment loans that would also fall under the CFPB's new rule.
Read more at INSIDESOURCES

Alchemy
We are a revolutionary merchant service and technology firm servicing the debt repayment industry

MaxDecisions, Inc. launches Enterprise A.I. & Machine Learning services - MaxDecisions A.I.

MaxDecisons Inc., a leader in direct mail marketing, analytics, and predictive modeling, today announces the official launch of Artificial Intelligence and Machine Learning as a service for the entire financial sector. "MaxDecisions, A.I." is now in general release for all our clients.

After 2 years of intense development in MaxDecisions, Inc's R&D Lab led by Stephanie Ma, MaxDecisions has rolled out the long-awaited Artificial Intelligence and Machine Learning models, model development processes and automation. This enables our clients to take advantage of the latest technology, technique, and algorithms to compete in today's market.

We have developed, redeveloped several generations of artificial neural network and machine learning models in our R&D Lab in the past two years to perfect not only the accuracy and robustness of our models but also independently developed a new process of A.I. model development and training process.

As the financial industry including banks, special financing companies such as patient financing, home improvement, and private student loans matures. The technology and methods much evolve as well to take advantage of the datasets made available to the financial sector. MaxDecisions, Inc. deep domain knowledge in banking and lending underlines our research and development efforts. These new algorithm and techniques are finally made ready for our clients to improve their fraud detection, credit risk management, and direct response marketing.
Read more at MaxDecisions

  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.

Like it or not, debt collectors may be texting and emailing you under new rules

The Consumer Financial Protection Bureau, under President Trump, already has moved to make life easier for payday lenders. It's expected any day now to do the same for debt collectors.

The bureau will unveil proposed rule changes that are likely to include explicit permission for debt collectors to contact people via text and email (and maybe social media).

The new rules also may provide greater latitude for bothering people by phone and limits on people's ability to challenge financial obligations.

In other words, more rights for debt collectors, fewer rights for consumers.

"The agency that Congress created to look out for consumers is now looking out for debt collectors and payday lenders," said Chris Peterson, director of financial services for the Consumer Federation of America.

He said debt collectors were pressuring the CFPB "to provide greater clarity that would allow them to be more aggressive." Read more at LOS ANGELES TIMES

microbilt
Alternative Credit Reporting

The risks of loan stacking. by Philip Burgess

As more small-business owners launch companies - 25 million Americans have started one within the past two years, according to figures from Babson College - many are finding success, but at the same time discovering that keeping their doors open costs more than they originally anticipated. To rectify the cash-flow shortfall, some are taking out second loans, thereby defraying these operating expenses.

But with more lenders to choose from, some are borrowing from multiple providers, taking advantage of more affordable interest rates in the process. Some don't stop there, taking out additional loans, sometimes to pay for the originals.

The strategy is called loan stacking, and while the activity has surged in recent years, its fraught with risks and land mines that can backfire for lenders who engage in the practice, even when borrowers pass the underwriting process with flying colors.

What is loan stacking?
As its title implies, loan stacking is where a borrower - typically a small-business person - already has a loan that's in effect but goes to a different lender and takes out another. There are public records that lenders can examine to see if a loan already exists, but in their haste, they may decide not to do their due diligence for fear of losing out on the business to a competitor.
Read more at MICROBILT

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

For women, relying on your husband as role model for money could be trouble

Who is your financial role model? If you're married and said your spouse, you may want to rethink your answer.

The latest CNBC and Acorns Invest in You Savings Survey found that 20% of married men said "their partner or their spouse" when answering that question. But women, at 32%, are much more likely to rely on their significant other.

The survey, conducted for CNBC by SurveyMonkey, polled more than 2,300 adults in March about various aspects of financial wellness.

For women, that can be a problem, because the financial stakes for them are higher. They typically earn less and are more likely to take time out of the workforce.

As a result, women have a $1 million earnings gap when they get to retirement, according to research from Merrill Lynch and Age Wave.

At that point, they have another challenge to contend with: longer life spans.
Read more at CNBC

Trust Science
Say "yes" to thin-file and no-hit borrowers with REAL alternative data and a fully compliant, AI-powered score, customized for your business.

Consumer Credit Reporting Agencies, (Literally) Keep America's Consumers Moving

At a time of heightened public awareness and concern about Big Data and cyber security, it's important to clearly understand the historical roles and socio-economic benefits of consumer credit reporting agencies (CRAs). CRAs are part of a highly regulated industry that creates democratic freedom and broad consumer engagement with the modern economy.

Enacted nearly 50 years ago, and enforced by the U.S. Federal Trade Commission, the Fair Credit Reporting Act (FCRA) promotes the accuracy, integrity, and privacy of information contained in consumer credit reporting agency files.

Since 1971, the U.S. credit reporting system has operated under the terms of the Act, although there have been several key amendments since that time. In 1996 for example, Congress reevaluated the FCRA in an effort to balance evolving national, local and personal interests. Key to achieving that balance was the preemption of state laws affecting provisions of the FCRA considered critical for maintaining a voluntary, market-driven credit reporting system that offers widespread, objective access to credit and the opportunities it provides.

The national credit reporting system regulated by the FCRA has worked well through the decades, functioning so seamlessly behind the scenes that credit reporting agencies are sometimes taken for granted, or viewed as dispensable. However, they create significant benefits for millions that should not be overlooked. Let's take a look, for example, at the vital role CRAs play in consumer mobility. Read more at TRANSUNION

ValidiFI
Redefining how financial service businesses measure risk and process payments.

Will Rolling Back Consumer Protections Rules Cause a Financial Crisis?

Will rolling back consumer protections cause a financial crisis? That is the claim of a recent article in The Hill by two former Washington Post business reporters. In particular, the article claims that an array of Trump administration actions represent "a scenario eerily reminiscent of events that drove the U.S. into a ditch in the Great Depression of the 1930s and the Great Recession 10 years ago."

That's a bold claim. And yet for such a prediction, the article provides little evidence to back it up. At best, it is a confused mix of hyperbole and fear mongering. In response to some particular claims regarding consumer protection (there are too many for one blog post), I've provided some brief responses below.

1. "Trump's undoing of the Dodd-Frank Act, which Congress passed in 2010 to end the unsustainable consumer debt that triggered the mortgage crisis and plunged the country into the worst downturn since the Great Depression -produces a toxic mix: rising consumer debt and decreasing oversight of lenders."

The "undoing" of Dodd-Frank presumably refers to S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act, a bipartisan piece of legislation passed in 2018. Yet that legislation merely tinkered around the edges of Dodd-Frank, predominantly raising certain restrictions placed on community banks under $10 billion is assets, which were far from the troubles of Wall Street. The vast majority of Dodd-Frank, let alone the enormous of amount regulation that preceded it, remains solidly intact. Read more at Competitive Enterprise Institute

TransUnion
Compete in the data-driven lending era
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