Short-Term, Small-Dollar Lending: Policy Problems and Implications

By | September 3, 2020

Short-Term, Small-Dollar Lending: Policy Problems and Implications

Short-term, small-dollar loans are consumer loans with reasonably low initial major amounts (frequently not as much as $1,000) with fairly quick payment durations (generally speaking for a small amount of days or months). Short-term, small-dollar loan items are commonly used to pay for cash-flow shortages which could happen because of unforeseen costs or durations of insufficient earnings. Small-dollar loans could be available in different types and also by a lot of different loan providers. Banking institutions and credit unions (depositories) could make small-dollar loans through financial loans such as for instance charge cards, charge card payday loans, and bank checking account overdraft protection programs. Small-dollar loans can be given by nonbank lenders (alternative service that is financial providers), such as for example payday loan providers and vehicle name loan providers.

The degree that debtor economic circumstances would be produced worse through the usage of high priced credit or from restricted use of credit is commonly debated. Customer teams usually raise concerns about the affordability of small-dollar loans.

The degree that borrower situations that are financial be produced worse through the utilization of expensive credit or from restricted usage of credit is commonly debated. Consumer teams frequently raise concerns about the affordability of small-dollar loans. Borrowers spend rates and charges for small-dollar loans that could be considered costly. Borrowers might also fall under debt traps, circumstances where borrowers repeatedly roll over current loans into brand brand new loans and afterwards incur more costs instead of completely paying down the loans. Even though weaknesses connected with financial obligation traps are far more often discussed within the context of nonbank items such as for example pay day loans, borrowers may still find it hard to repay balances that are outstanding face additional fees on loans such as for example charge cards which can be given by depositories. Conversely, the financing industry usually raises issues about the reduced option of small-dollar credit. Regulations directed at reducing charges for borrowers may end in higher prices for loan providers, perhaps restricting or reducing credit access for economically distressed people.

This report provides a synopsis of this consumer that is small-dollar areas and relevant policy problems. Explanations of fundamental short-term, small-dollar cash loan items are presented. Present federal and state regulatory approaches to customer security in small-dollar financing areas may also be explained, including a directory of a proposition because of the Consumer Financial Protection Bureau (CFPB) to implement requirements that are federal would behave as a flooring for state laws. The CFPB estimates that its proposition would end up in a product decrease in small-dollar loans made available from AFS providers. The CFPB proposal happens to be at the mercy of debate. H.R. 10, the Financial SELECTION Act of 2017, that was passed away by the House of Representatives on June 8, 2017, would avoid the CFPB from working out any rulemaking, enforcement, or just about any other authority with respect to pay day loans, automobile name loans, or other loans that are similar. This report examines general pricing dynamics in the small-dollar credit market after discussing the policy implications of the CFPB proposal. The amount of market competition, which might be revealed by analyzing selling price characteristics, might provide insights concerning affordability and supply choices for users of specific small-dollar loan items.

The small-dollar financing market exhibits both competitive and noncompetitive market prices characteristics. Some industry monetary information metrics are perhaps in line with competitive market rates. Facets such as for example regulatory barriers and variations in item features, however, limit the ability of banks and credit unions to take on AFS providers within the market that is small-dollar. Borrowers may choose some loan item features made available from nonbanks, including the way the items are delivered, when compared to items provided by old-fashioned institutions that are financial. Because of the presence of both competitive and market that is noncompetitive, determining if the costs borrowers pay money for small-dollar loan items are “too high” is challenging. The Appendix covers how exactly to conduct price that is meaningful utilizing the apr (APR) in addition to some basic information regarding loan rates.

Short-Term, Small-Dollar Lending: PolicyВ Problems and Implications


  • Introduction
  • Short-Term, Small-Dollar Item Explanations and Selected Metrics
  • Breakdown of the present Regulatory Framework and Proposed Rules for Small-Dollar Loans
  • Methods to Small-Dollar Legislation
  • Breakdown of the CFPB-Proposed Rule
  • Policy Issues
  • Implications for the CFPB-Proposed Rule
  • Competitive and Noncompetitive Market Pricing Dynamics
  • Permissible Tasks of Depositories
  • Challenges Comparing Relative Rates of Small-Dollar Borrowing Products


  • Dining Table 1. Overview of Short-Term, Small-Dollar Borrowing Products
  • Dining Dining Table A-1. Loan Expense Evaluations