Category Archives: Uncategorized

The CFPB is making it clear that it is going to hold payment processors responsible for it’s customers actions.   The CFPB  charged one of the nation’s largest payment processors, Washington-based Meracord LLC, for processing $11.5 million in illegal upfront fees from consumers on behalf of debt-relief service providers. The collection’s companies were Payday Loan Debt […]

A must read in Time Magazine titled, Meet the New Payday Loan Customer: Middle-Class, Well-Educated. What I found interesting about the article: A recent study conducted by the Urban Institute found that, in 2011, 41% of American households reported using what the agency calls “alternative financial services,” according to Boston College’s Center for Retirement Research. That’s up from 36% in 2009, […]

What’s interesting about this settlement is that the five payday loan companies involved were located inside the state of New York.   Does this mean that fines do not work with lenders outside the state? Also, $3.2 millions among five companies is not a large portfolio. “The five companies have agreed to pay more than […]

Don’t get me wrong…..it’s definitely good news.  Until we hear from the third party processors via their banks, let’s not celebrate just yet.  This sums it up: “Institutions could be exposed to financial or legal risk should the legality of activities be challenged.” Basically, what they’re saying is if you’re a bank or a third […]

What’s unknown here is how these types of rulings affect the primary creditor.  Back in July, I wrote about Fair Debt Collections Act titled: Fair Debt Collection Practices Act And The Primary Creditor.  There is a huge grey area as this pertains to the primary creditor. In a settlement announced Monday, the FTC brought its […]

In the next two weeks, the FDIC is going to issue a letter explaining how how banks should do business under U.S. rules with online lenders who may run afoul of state laws.  The FDIC promise comes in the wake of demands from Republicans in the U.S. Congress to explain why it has pressured banks to […]

This California Senate bill 318 is creating rules for loans between $300-$2,500.  I glanced at the bill and it is textbook terrible.  Here are the low lights.  Beyond the price control here, it’s poorly planned.  The compliance will stink on this one. 36% interest rate cap (essentially). Can only refinance once. Can only refinance after […]

This is good news, but is it the reality?  Bloomberg writes: Payment Group Says U.S. Banks Can Work With Legal Online Lenders. I’m sure if you’re processing through Bank of America and you’re Cash Net USA it is, but most lenders can not get an account with a major bank.  They’re stuck going through 3rd […]

“The man who passes the sentence should swing the sword. If you would take a man’s life, you owe it to him to look into his eyes and hear his final words. And if you cannot bear to do that, then perhaps the man does not deserve to die.” ― George R.R. Martin, A Game of Thrones […]

“A bruise is a lesson…and each lesson makes us better.” ― George R.R. Martin, A Game of Thrones Ironically, after years of worrying about the CFPB, it was the New York Department of Financial Services that drew first blood.  In a WSJ article titled CFPB Head: Limited Control Over Online Lending Richard Cordray states “State authorities enforce state […]