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Nov 18 2009, 4:56 pm

On Poverty, Interest Rates, and Payday Loans

Felix Salmon responds rather pungently to my post on debt.  I certainly didn't mean to imply that Felix's position is unreasonable--it's not, and a lot of people hold it.  I just think it's tricky.

I'll cover some of our disagreements in a minute, but I think this is really interesting:

McArdle is far too generous to the lenders here. For one thing, I made it clear in my post that credit cards are very good for transactional credit: if you need to pay the car-repair shop today, using a credit card is a great way of doing so. But you should also have a good enough relationship with your bank that by the time the credit-card bill comes due, you can pay it with the proceeds from a personal loan or line of credit.

Secondly, I don't think for a minute that we should deny the poor credit; in fact I'm on the board of a non-profit institution which exists to provide credit to the poor, and I'm all in favor of that. It's credit cards I don't like, with their high fees and interest rates (and there are even exceptions to that rule, such as the ones provided by many credit unions). And I really dislike payday loans, which are pretty much universally predatory, especially when compared to similar products from community development credit unions.

Megan's conceptual mistake here is clear when she says that "credit extended to the poor carries high interest rates to cover the default risk". But in fact the interest rates on credit cards are really not a function of default risk at all. Mike Konczal had a great post on this back in May, where he showed pretty conclusively that credit-card interest rates were all about maximizing profit for the issuer, rather than compensating for default rates. And payday loans are even worse.

What earthly grounds does Megan have for saying that the number of people made worse off by payday loans is smaller than the number of people made better off by them? I suspect she considers the alternative to be no-credit-at-all-nohow-noway. But that's not what anybody is proposing. I, for one, think that credit should be available to the poor, very much so. But not in the quantities and at the rates that it's been available until now. There is such a thing as too much credit, and we crossed that line long, long ago.


It's an odd fact that poor people shun bank accounts at an astonishingly high rate. Rather than pay $10.00 a month for a checking account, they'll pay more than that to a check cashing place.  Of course, it's not like banks are going after those clients, because they're not very profitable--small accounts still have almost all the transaction costs and overhead of large ones.  But why don't the customers go after the banks?

The plausible reasons I've heard:

- Check cashing places give you the money immediately

- Poor people are disproportionately subject to judgments and garnishments that make it preferable to operate in cash

- People working off the books don't want a trail for the IRS to follow

- For people with low incomes, the costs associated with a mistake--bounced check fees, for example--can be devastating.  But if you don't have the fees, people will overdraw their accounts.

- Check cashers keep longer attractive hours and have better service

As Felix could no doubt attest at great length, this problem has proven hella stubborn.

The problem of payday lenders and credit cards, however, is not a problem of the unbanked.  If you don't have a relationship with a bank, you almost certainly do not have a credit card, and you definitely aren't using a payday lender.

So why are people using credit cards and payday lenders?

Credit cards have low transaction costs, which is why, as Felix argues, people use them for sudden emergencies.  Many of them would be better off if they did go to their credit union for a personal loan to pay off the balance.  On the other hand, if you're planning to pay off the balance in a couple of months, that's overkill--and the loan inquiry will ding your credit.

Payday loans are a different question.  There's a lot of literature on them, but most of it agrees on a few points.  For our purposes, the salient characteristics of payday borrowers are a) they have little-to-no money in the bank b) they have moderate incomes and  c) they are fairly severely credit constrained.  Virtually all payday borrowers use some other sort of credit (Stegman and Faris, 2003). At least 60% of them have access to a credit card (Lawrence and Elliehausen, 2008).  73% of them have been turned down for a loan in the past five years, or received less credit than they asked for.   If they're turning to payday loans, it's because they have maxed out those other forms of credit, and they have some pressing cash flow need.

Payday borrowers do not necessarily turn to payday lending out of ignorance; a majority of them seem to be aware that this is a very, very expensive form of financing.  They just have no better options.

The biggest problem with payday loans is not the one-time fee, though that is steep; it's that people can get trapped in a cycle of rolling them over.  Paying $15 to borrow a few hundred bucks in an emergency is bad, but it's probably manageable for most people.  Unfortunately, since payday borrowers are credit constrained, have little savings, and are low-to-moderate income, they often have difficulty coming up with the principal when the loan is due to pay off.  The finance charges add up, making it difficult to repay the loan.

According to Lawrence and Ellihausen, about 40% of payday borrowers fall into that problem category:  they have rolled over a loan five or more times in the past year. A hard core of about 20% had rolled over 9 or more advances.

Judging who is worse off is a pretty tricky task.  Would payday borrowers be better off if they had no other debt, and could go to their credit union for a tidy personal loan?  That's unquestionable.  By the time they're at the payday loan stage, however, that doesn't seem as if it's usually an option.  I'd say that the people who are rolling over 9 or more loans are definitely worse off, the people rolling over 5-9 loans are probably worse off, and the majority who are rolling their loans over no, or a few times are probably better off, given the circumstances they were in when the time came to get the loan.  People who roll over loans only a few times are not trapped in a debt cycle, and (I'd guess) are unlikely to have been using the loans for ordinary expenses.

There's some experimental and empirical evidence to support this.  Wilson, et al (2008) built an experimental model of credit-and-cash constrained households, and found that adding payday loans contributed significantly to household financial survival in the lab.  Which seems to also be true in real life, according to their paper:

Georgia banned payday loans in May 2004 while North Carolina banned them in December 2005. These two events provide the authors with an opportunity to empirically investigate several effects of the removal of payday loans on household behavior. Morgan and Strain find that relative to households in other states, households in Georgia bounced more checks, complained more frequently to the Federal Trade Commission about lenders and debt collectors, and were more likely to file for bankruptcy under Chapter 7 after the ban of payday loans . . . The results for North Carolina, which the authors regard as preliminary, given the shorter period in which payday loans have been banned, are similar to those for Georgia.   
There is, of course, the question of what happens to people between the time when they had no debt, and the time when they need the payday loan.  If we could constrain them during that period from maxing out their available credit, they'd never need a payday loan.  People who have maxed out their credit and are getting turned down for loans could probably have used an intervention that would force them to match income to outflow.

But I'm not sure how you do that.  Say we slap on a usury law that makes credit card lending to poor people unprofitable, so people use personal finance loans instead.  Well, the people who are getting payday loans now would, in this alternative universe, have already maxed out this line of credit.  How do we know that?  Because they seem to have done it in this universe. I don't know whether that's because they're irresponsible, or because they had a string of really crappy bad luck.  I'm not sure it matters.

The core problems we would actually need to solve to get rid of payday loans are first, that some people have marginal incomes and no capital, and second, that when credit is available, some of those people do not exercise the incredibly tight spending discipline which is required to achieve financial stability on such an income.  Because their incomes are marginal, and the lives of the working poor are fraught with all sorts of extra problems, like cheap cars that break down constantly and landlords who turn the heat off, the people who do not keep very tight control of their money are fairly likely to end up in a place where they have exhausted all other credit lines, and are forced to pawn something, hock their car title, or take out a payday loan. 

And those loans are jaw-droppingly expensive.  Even non-profit payday lenders apparently charge about a 250% APR, because the loans have a 10-20% default rate, and the transaction costs on lending small amounts are very high. Of course, the profits are usually quite substantial, with APRs often double the non-profit rate . . . and even I have to wonder how a guy who made his fortune lending money at 600% o society's most financially unstable people, smiles at himself in the mirror every morning.

But while in principle, I agree that many poor people would be better off if they were able to borrow a lot less money at better rates (though even then, I always wonder if I'm not just imposing my monetary time preference on others).  Only when I look at any given rule aimed at accomplishing this, it always hurts a lot of people, even as it helps others--I think the last twelve months have proven fairly conclusively that the supply and price of credit are not entirely unrelated to default risk.  While it is absolutely true that credit card issuers maximize their returns through hefty stealth charges, and payday lenders charge absolutely rapacious interest rates, it is also apparently true that these awful loans often help avoid even worse fates.  And I don't see any way to cut off the credit to people who are ignorantly or irresponsibly getting into trouble, without also cutting it off to a bunch of people who need it.

So I think focusing on the lender side is usually a mistake, though I can't say I'd be sorry to see caps on what payday lenders can charge.  The lender side makes us indignant, because hey, they're getting rich by charging outrageous rates to those least able to pay them!  But if we want to actually improve the lives of the borrowers, we need to intervene before they get to the payday loan point, rather than try to stop them from getting one once they're there.  Felix is doing God's work on just that problem, as are many other people in many other ways.  I think we'll be better off when payday lenders go out of business due to lack of demand, not prohibited supply.

Comments (12)

Megan,

That's quite a post. Instead of tackling the whole thing, I want to focus on one key question you pose: why do the poor turn to payday lenders?

There's a very simply answer that you don't offer - geography. Payday lenders go out of their way to open storefronts in low-income neighborhoods. Banks don't.

It's incredible how strongly determinative a role spatial geography plays in financial decisions. There've been a series of compelling investigations and academic studies that have examined the locations of subprime lenders. Overwhelmingly, they were located in comparatively poor areas. As they got snapped up by national financial institutions, and converted into affiliates, banks continued to place branches of their primary brands in affluent districts, and to put only subprime affiliates in poorer neighborhoods. There's a tragically large segment of subprime borrowers, including many who have entered foreclosure, who would have qualified under ordinary lending guidelines for prime-rate mortgages. They weren't offered those mortgages, because they walked into their local lending office to talk to a loan officer or mortgage broker. Had they driven a mile to a nicer part of town, and walked into a branch operated by the same parent company, they would have been offered a regular loan - and probably could have kept their houses.

The same is true of payday lenders. And they're ubiquitous. To quote the NYT article to which you link, "Payday loan stores, which barely existed 15 years ago, now outnumber most fast-food franchises." What the study you cite - about Georgia and NC - actually demonstrates is that simply banning payday lending isn't enough, unless it's paired with a sustained effort to offer alternatives. Take away all the payday lenders, and the big national banks still don't move into these underserved markets. Borrowers under extreme financial pressure may not have good access to transportation, and are certainly unlikely to have either the financial sophistication or the time and tools to locate a decent deal. If the loan shark on the corner gets banned from the market, their needs to be a Co-op or a Credit Union that moves in to replace it.

Markets aren't always efficient. It's entirely possible to profitably offer short term, non-usurious personal loans to people in financial distress, and to make a small profit doing it. Numerous local institutions do just that. But since they're almost always small, often operated on a non-profit basis, and tied to local communities, they tend to lack the resources or the inclination to expand aggressively. Certainly, as long as extreme payday lending remains legal, such institutions won't be able to compete effectively. They're all looking for the same consumers, who have little information about financial services, and the payday lenders will be able to operate many more locations and to swamp non-profits and local lenders with advertising that they can't afford to match. It's very difficult to make a rational choice between the option you know, and the one you haven't heard about.

Good government programs respond to market failures. In this case, the government needs a two-pronged approach: a phased ban on payday lending, to allow time for alternatives to take root, and a series of incentives to attract capital to low-cost, short-term lending. If Credit Unions were as numerous as fast food joints, most of the payday loan problem would disappear overnight.

Dan (Replying to: Cynic)

I had a similar response planned, but yours is more than sufficient.

Great post!

Payday loans, credit cards and personal loans are segmented market responses with different products at different price points (maybe) to achieve similar ends. People choose alternatives among products everyday. It is irrelevant if an outside analysis concludes one choice is more cost effective or better in some paternalistic sense. If consumers did not voluntarily choose the products, they would not exist.

For example, one can go the grocery store and buy uncooked beef and fresh broccoli and go home and cook a Chinese restaurant version of beef and broccoli, one can go to an all-night diner and takeout their version of Chinese beef and broccoli or one can go to a Chinese restaurant and order the same dish for takeout.

How does a third party determine which is better? Obviously all three options exist because to different population segments, or to the same population segments at different times, anyone of the three is a preferred choice based on many variables including cost, convenience, taste, etc. Is it relevant that one maybe cheaper, one may contain less sodium, another less fat or another taste better to some selected panel? Or that in a survey people respond in ways that do not reflect their actions? Should we ban some choices or require conformity because on some scales one is healthier, cheaper, tastier, etc.

Banking and lending products are not any different than other consumer products except they are more heavily regulated and there is much more government paternalism, especially towards certain population segments which seems to vary over time, and can and has been minorities, less educated, poor, homeowners, credit card users, etc. Isn't it just legislative elitism and paternalism of those with the power to promote a specific mandated legislated choice acting out their beliefs that they know better what the consumer actually wants than the consumer? They usually have to assume some market failure (but affecting others they have to protect) or some irrationality in choices (again of course it is the other group that needs protecting). Let people maximize their own welfare through their own choices instead of allowing arrogance of a few dictate choice outcomes for others.

Cynic explained the problem with "choice" as you describe it. There are not viable alternatives available in most cases.

Let's take your beef and broccoli example. In "poor" neighborhoods, the local store does not offer fresh broccoli; but the inexpensive unhealthy alternative of prepared food is there - ekeing out a profit.

There are alternatives, but no true choice. The Libertarian fantasy of "options on every corner" does not exist. The "market" is at once altruistic, unitary, and predatory. And each state of condition requires monitoring as the lines between them blur.

Cynic (Replying to: Dan)

Heh. And now you beat me to the punch, and got the same point across in a third of the space. Well put.

That's a nice recitation of libertarian cant. The problem is that you're inhabiting one reality, and payday borrowers one that is entirely different. The example you offer is actually helpfully illustrative.

For example, one can go the grocery store and buy uncooked beef and fresh broccoli and go home and cook a Chinese restaurant version of beef and broccoli, one can go to an all-night diner and takeout their version of Chinese beef and broccoli or one can go to a Chinese restaurant and order the same dish for takeout.

Well, those may be the choices in your neighborhood. But the storefront sandwiched between the payday lender and the cheap Chinese restaurant isn't going to be a grocery store, because in America's poorer neighborhoods, there are hardly any grocery stores. Instead, there are corner convenience stores and bodegas. They charge higher prices for their food. The food they offer is of inferior quality, and the selection is tiny. Good luck buying either fresh ground beef or broccoli - although an overpriced frozen dinner with those ingredients, chock full of salt and fat, is likely to be on offer in the freezer case.

So why do consumers patronize bodegas, if full-service grocers offer better food at better prices? It's not because they're exercising some essential freedom, or illustrating the quirks of consumer choice. They're taking the option that's available to them. Maybe they just got off a twelve-hour shift, and are too tired to go to some other neighborhood for food. Many don't own cars, and have to walk or take public transit, which is tough to do with multiple grocery bags. If they have children, the amount they can carry and the distance they can travel will be further restricted. And then there are the cultural biases - local storefronts feel comparatively safe, and consumers are often reluctant to believe that people who share personal or cultural bonds would exploit them.

More intriguingly, from an economics perspective, is why grocery stores don't simply move into dense urban neighborhoods to service the working poor. It's analogous to the national bank question. There are a bunch of interesting reasons. The simplest is straightforward lack of imagination - the conventional wisdom is that you can't make a profit there. But there are other constraints. It's difficult to obtain a large enough parcel of land. Banks are more reluctant to extend commercial loans even to highly profitable businesses if they're located in a bad neighborhood, and groceries are always a low-margin business. It requires a degree of local knowledge and tailoring - the dense ethnic enclaves of working-class neighborhoods have particular tastes and needs that chain stores may have trouble divining. But, as it happens, there's a colossal business opportunity at stake. Some cities - notably, New York - are now using zoning rules to lure grocers to poor, urban areas. And once they set up shop there, they typically thrive. The best performing grocers in the downturn are stores like Dollar General that have taken the time to learn these markets. There are signs of change.

Lending is a similar market. If your neighborhood has a dozen payday lenders and no bank, where do you think you're going to turn for credit? To the bank in the other part of town, where they don't speak your language (either literally or figuratively) and don't appear to want your business? Or to the guy in the payday store on the corner, whose kid goes to the same school as your kid?

Consumers don't sit down, carefully chart all of their options, compile the costs and benefits, and make a decision. I had thought the myth of the rational actor had been burst, once and for all, by the new work in behavioral economics. Here's hoping it will be, soon.

Dan (Replying to: Cynic)

It's not about behavioral economics, it's a cultural and socio economic disincentive. Ta-Nehisi Coates did a blog post on it a while back.

There are the same economic (profitability) risks in establishing a grocery store in a middle class neighborhood as in a low income neighborhood. So the theory washes.

Agreed about the banks as well.

The story of the economic wasteland that is the "urban" or "inner-city" or "low income" neighborhood would be enough for a series of books.

Milton Recht (Replying to: Cynic)

It is again cultural paternalism and a false exportation of your large city experience as a national generality. The larger, older cities, such as NYC and Chicago, etc., have extremely restrictive zoning requirements and other cost disincentives which even keep out many stores which want to open, such as Walmart, large box stores, and large supermarkets. In areas of the country without these restrictive zoning requirements and without the elite hatred of box stores, the poor and ethnic groups do not have the shopping limitations you mention.

In any neighborhood where there is a bodega, people are eating healthy foods. It is just that it is ethnic foods that most Americans who promote their paternalistic elitism do not eat in their homes, such as rice and beans, kale, black-eyed peas, plantains, casaba and many others. Of course, there is no broccoli because it is not a staple of their diet. As it would not be a staple of an Englishman's diet and if there were neighborhoods that were primarily comprised of people from England, the stores in their neighborhoods would also not carry the food you are most familiar with as an American and you would think it was unhealthy.

Furthermore, in the wealthier suburban neighborhoods, there is no shortage of McDonalds, Burger Kings, Pizza Huts, KFCs, etc plus pizza and Chinese food delivery. Many suburban children are eating these foods regularly. Busy parents are busy parents whether in suburbia or inner cities and both look for convenience.

Banco de Ponce, Banco Popular and other ethnic banks opened years ago in ethnic neighborhoods as did payday lenders. Citibank and other large banks have for years made an effort to hire people for their retail banking branches who could speak Spanish and other foreign languages to accommodate neighborhood differences. It is a nice story you tell, but none of it is reflected by the actual daily experience of minorities and poor. One has only to go to 34th St area in NYC to a Jacks, or Conways discount clothing stores to know that minorities and others looking to save money will travel to shop.

It is just an inability of some of the middle and upper class cognoscenti to accept, after studying an issue and after making a reasoned decision, that someone else may rationally decide not to follow their example and not buy a hybrid or not drink non-fat or soymilk, etc. It is not that the other decision is wrong; it is more reflective of the insecurity of the paternalist that another decision maybe just as rational and valid. A different decision is not a wrong decision, no matter the type or depth of analysis that motivated the first decision.

If someone is choosing a payday lender over a bank without overt threats to do so, then other people do not have the right to second-guess that decision, assume it is an inferior choice, and pass legislation restricting choices. It is not libertarianism. It is just recognition that people should not be banking or shopping missionaries promoting their own way of doing things to those who act differently.

If risky, high-interest loans are made illegal, only illegal operators will make risky, high-interest loans. And historically, they have done a lot worse to defaulting borrowers than collect too much interest. Just pointing out that there are worse things than financial stress.

Megan - Thank you for pointing out the significant bodies of experimental and empirical research on the subject payday loans that have been produced by leading economists and professors at some of the nation's foremost colleges, universities and financial oversight institutions.

The majority of this research suggests that within the current consumer financial marketplace, short-term (payday or cash advance) loans provide a practical solution for middle class Americans with limited access to traditional consumer credit versus the costs of overdrafts at both Banks and Credit Unions, bounced checks, and late/overdrawn penalty fees imposed by credit card companies and other institutions.

As a matter of fact, according to a 2008 study by the FDIC, 75% of bank holders overdraft at least once annually and 9% overdraft five times or more. With an average overdraft fee of $27(at the time of the study...it's increased significantly since last year's downturn) on an averdraft overdraft transaction of $36, these consumers are paying a minimum of $0.75 per dollar borrowed from the BANKS OR CREDIT UNIONS. These "overdraft protection loans" are available for only three or four days before the majority of these institutions begin imposing an addition $5 to $8 daily overdraft surcharge. A $100 overdraft check held for 14 days by a BANK or CREDIT UNION could result in fees of $115 or more and an APR of 2,990%

By contrast the $15 or $20 fee charged by short-term lenders($0.15-$0.20 per dollar borrowed) is 1/4 to 1/5 the INITIAL cost of the BANK or CREDIT UNION alternative and is 13% to 17% of the cost for 14 days.


This is agreed upon by consumer "advocates" and researchers alike:

Jonathan Zinman, Dartmouth College: “Most substitution seems to occur through checking account overdrafts of various types and/or late bills. These alternative sources of liquidity can be quite costly in both direct terms (overdraft and late fees) and indirect terms (eventual loss of checking account, criminal charges, utility shutoff).”

Sheila Bair, Current Chair, FDIC: “When used on a recurring basis for small amounts, the annualized percentage rate for fee-based bounce [overdraft] protection far exceeds the APRs associated with payday loans.”

Federal Deposit Insurance Corporation: “…a customer repaying a $20 POS/debit overdraft in two weeks would incur an APR of 3,520%; a customer repaying a $60 ATM overdraft in two weeks would incur an APR of 1,173%; and a customer repaying a $66 check overdraft in two weeks would incur an APR of 1,067%.”

Coalition of 90 Consumer Groups: “Unlike payday lending programs, the extraordinarily high APRs in fee-based overdraft programs are never disclosed as such, and none of the other consumer protections are provided. Moreover, fee-based overdraft programs are aimed at the very same customers that payday lenders are seeking…and the costs rival or exceed those of payday lending.”

Jean Ann Fox, Consumer Federation of America: "If a bank lends you $100 and charges you a $20 fee -- and then you pay the money back in two weeks -- that's an annualized interest rate of 520%. It's worse than a payday loan."

Where you all drive off course is in the suggestion that these loans somehow generate "huge revenue" and can be offered at significantly lower rates.

A National independent study by Ernst and Young found thatit costs the average payday lender approximately $13.89 to offer a $100 loan. On a pre-tax and pre-interest basis, multi-line payday advance lenders earn an average profit of $1.37 per $100 of loan principal issued for two weeks.

The "models" that are portrayed as providing short-term credit for less, are in the majority of case (example of the military and state employee offerings), highly subsidized by tax dollars. Prospera Credit Union’s Good Money payday loan, considered the model payday loan alternative, charges customers $9.90 per $100 borrowed. The product is break even for the credit union and offered in partnership with Goodwill, a non-profit, tax-exempt charity.

Banks like US Bank, Fifth Third and WellsFargo have begun offering payday loan products for $10 per $100 in certain states, but the terms of these products are often far shorter than the two weeks offered by payday lenders, and the customers who use these products are the same who are paying fees through overdraft protection.

The short-term lending industry currently generates approximately $5.5 Billion in fees on $45-$50 Billion in loans annually. Overdraft fees of Banks and credit unions are estimate to generate seven times than much ($35 Billion) and credit card penalty fees another $20 Billion.

Unless the non-profit community has pockets deep enough to break even while supplying hundreds of Billions in credit and the government plans to subsidize these transactions with our tax dollars, it seems to me that the privately held, unsubsidized, no bailout recipient short-term, payday lenders are the BEST SOLUTION unless someone plans to change the entire economic market system and salary structure of our entire country!

Yes, ladies and gentleman. Pull back the curtain and you'll find...Jeff Kursman! He's the Director of Public Relations at Axcess Financial, the parent company of Check 'n Go.

How about some basic standards of disclosure, Jeff? For example, if you're in the paid employ of the industry on behalf of which you're advocating, try telling people that when you post a long and tendentious argument on a public message board. What done here is more generally known as "sock-puppeting," and it's about as sleazy as the rest of the practices in which your industry routinely engages.

Just for the heck of it, I'll also point out that the best defense the payday-loan industry can muster is that some other practices - notably, overdraft charges - are even more exploitative and usurious. Bravo, Mr. Kursman. You're entirely correct. But somehow, I'm not comforted. Assault is less serious than attempted murder, but I'd rather not fall victim to either one.

Cynic -

There is no curtain. Yes, I am the Director of Public Relations for Axcess Financial and it's sister company Check 'n Go. The depth of the knowledge I shared would hopefully reflect upon my role within the industry. My apologies if some readers felt that my disclosure was inadequate. However, I am secure enough with the reason, research and statistics behind my arguments to use my name when posting responses...

Can you Mr. or Mrs. "Cynic" state the same? [By definition: A sockpuppet is an online identity used for purposes of deception within an online community. In its earliest usage, a sockpuppet was a false identity through which a member of an Internet community speaks with or about himself or herself, pretending to be a different person,[1] like a ventriloquist manipulating a hand puppet.] "JKursman" is clearly not a deceptive identity of Jeff Kursman. I'm 100% comfortable with who I am and who I represent. However, who is "Cynic"???

As for my "long and tendentious arguments," I believe you have now offered three tretises yourself, obviously trying to obscure your inaccurate and unsubstantiated claims with a verbal Dysentery of crossword puzzle vocabulary. Your use of multi-syllabic words, however, does not refute the realities of the marketplace and the volumes of research by world reknown economists, Fed Reserve researchers, the FDIC, Bretton Woods and numerous professors from such distinguished institutions of higher learning as Dartmouth College, Colby College and the University of Chicago (to name just a few) supporting the value of short-term loans versus overdrafts, late penalties and other more expensive alteratives of banks and credit unions.

Compare the $5 Billion dollar short-term loan business with the $50 Billion in overdraft fees collected by banks and credit unions or the $20 Billion in credit card overlimit and late penalties. We're not working out of 40-story heaquarters in every city in America or receiving taxpayer bailouts, but we are providing needed credit to million of American families.

The short-term lending industry is among the most regulated and transparent segments of the financial services industry. The reality is that 19 million working and middle class U.S. consumers, with an average educational attainment level surpassing that of the average total US population, are comparing financial products in a challenging free market economy and choosing the services that they feel are in their best financial interest.


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