Does Lender Behavior Support CFPB’s Hypothesis That Installment Loans Are Increasingly Unaffordable as Rates Increase? By: Rick Hackett CFPB (the Bureau) defines “covered longer term loans” that will be subject… Read More
By: Rick Hackett In a recent White Paper, we analyzed the ability-to-repay (ATR) of a large sample of storefront payday borrowers, using the CFPB’s recently proposed method of computing residual… Read More
In Report #8 published on nonPrime101, this team asked the question: can a historical population of payday loan borrowers qualify for an installment loan under the standards laid out in… Read More
NonPrime101 finds that the CFPB proposal will reduce credit access to storefront payday customers by 81.3% to 90.5% On June 2, 2016, CFPB proposed rules for payday, auto title and… Read More
The Consumer Financial Protection Bureau’s (CFPB) proposal for regulating smalldollar, single-payment (a.k.a. payday) loans significantly threatens the continued operation of that industry. Consumer behavior in that market involves a majority of consumers either… Read More
By: Rick Hackett Clarity Services, Inc., a consumer reporting agency, has a longer duration, and likely larger data set, than the Consumer Financial Protection Bureau (CFPB) had available for its… Read More
By: Rick Hackett This report uses a statistically valid random sample of a constant pool of 1,000 users over 3.5 years, with a full year run-off period after the sampling… Read More
The Clarity small-dollar markets research team has access to two very large data sets of small-dollar applicants and borrowers. First, the Clarity production data contains information from almost 300 lenders… Read More
Analysis of the Relationship of Payment-to-Income Ratio to Defaults in Online Installment Loans In its recent outline of proposed regulations, the CFPB suggested it may allow a “safe harbor” from… Read More
This report analyzes the structure and pricing of small dollar loan products originated through the Internet, as reported to Clarity Services, Inc., with a particular focus on the structure and… Read More
