The bottom line is the underserved suffer from cash flow deficits that are a reflection of low wages and an ever increasing cost of living. The major socioeconomic factors contributing to these trends merit separate public policy approaches and regulatory changes that are not necessarily in the purview of the products offered by financial institutions. However, if these institutions are going to target this market and they want to do so responsibly, they need to provide small-dollar products that spread the cost of an income shortfall over a period of time and at an affordable cost of a 36% APR. The traditional payday loan structure should not be the standard by which innovation in this credit space is measured.
Liana Molina and Andrea Luquetta are with the California Reinvestment Coalition, a consumer advocacy group.






















































What if Wells Fargo led the way and said it would cap it's direct deposit payday loans at 38% APR? They'd still make money, wouldn't be putting poor people into even deeper cycles of poverty, and would restore some trust in banking institutions.
I wish one day these advocate groups would pool their money and originate loans as they propose without subsidies or grants. Perhaps after they have they have gone through the process of operating a financial institution and meet the myriad demands upon them, they could come to us with wisdom and experience.
PS. Without needing to refute all the authors' false assertions, in California, it is illegal to renew a payday loan. Loans must be paid off in full prior to a new loan being originated.
The project, whose principal objective was to show that small dollar loans could be made at 36% APR or less and then dropped in the final report because it failed on that point,demonstrated that banks could not acheive either scale or profitability, even when they moved the top range from $1,000 to $2,500.
The project was a progressive advocacy objective forced unto banks through the FDIC's COME-In that is heavily weighted with non-profit advocates and community activists.
These groups are now using the American Banker name and this article to promote this incorrect information to further their campaign against commerically sustainable lenders.