'The IRS Should Sell Cereal': Comments of the Week

Seeing impending payday lending rules from the Consumer Financial Protection Bureau as reason why banks should not offer small-dollar loans:

"Given the loan and borrower characteristics associated with payday loans that you have outlined quite well, why would any institution choose to step into the space when the rulemaker, examiner, judge, jury and executioner is a government agency with unchecked power, questionable ethics and a hostile view towards banks. A bank would have to invest enormous resources into creating a program that would prevent any errors in decisioning, recordkeeping, servicing and reporting. Given the risks, the ROI wouldn't be worth it."

On why payday lenders should be able to advertise on Google:

"I think most people have enough sense to know that this is a fair value and consumers can make the economic decision to either pay the fee or pass on the loan. No one is being forced against their will to borrow money from payday lenders. We should allow the free market to work and Google should [rescind] their ad ban."

On a study suggesting credit unions are using designations for serving low-income areas as a way around the federal cap on member business lending:

"The key policy question isn't how much market share is the credit union gaining or how large are their purported benefits to consumers but rather is the credit union industry something that still needs a large public subsidy."

Disagreeing with an op-ed that calls for publicly disclosing Camels ratings:

"In [Community Reinvestment Act exams], examiners are spooked by all the scrutiny and question whether it's worth it to assign an unpopular rating. I think we could expect a similar climate with public CAMELS, so I agree that disclosing them is not a good idea and would not advance regulatory supervision. If we do go that route, though, how about stickers to place on bank front doors: red, for enter at your own risk; yellow, for proceed with caution; green, for all systems go?"

Related Article: Make Camels Ratings Public Already

In response to the argument that banks should focus on older adults instead of millennials:

"In my opinion, while older generations may generate the most potential revenue, the older millennials are the most likely to move to a new financial institution, thereby providing a great deal more potential for most organizations. Using one of several digital credit tracking services, combined with multichannel retargeting and social engagement tools, the older millennial is a potential gold mine for organizations with a strong digital and credit offering."