Short-Term, Small-Dollar Lending: PolicyР’ Problems and Implications


  • Introduction
  • Short-Term, Small-Dollar Item Explanations and Chosen Metrics
  • Breakdown of the latest Regulatory Framework and Proposed guidelines for Small-Dollar Loans
  • Ways to regulation that is small-Dollar
  • Summary of the CFPB-Proposed Guideline
  • Rules Dilemmas
  • Implications associated with CFPB-Proposed Rule
  • Competitive and Noncompetitive Market Rates Characteristics
  • Permissible Strategies of Depositories
  • Challenges Comparing Relative Rates of Small-Dollar Financial Products



Short-term, small-dollar loans are consumer loans with fairly low initial principal amounts (frequently lower than $1,000) with reasonably brief payment durations (generally speaking for a small amount of days or months). Short-term, small-dollar loan items are frequently employed to pay for cash-flow shortages which will happen as a result of unanticipated spending or durations of insufficient earnings. Small-dollar loans may be available in different types and also by various types of lenders. Banking institutions and credit unions (depositories) makes small-dollar loans through financial loans such as for instance charge cards, charge card payday loans, and account that is checking security products. Small-dollar loans can be given by nonbank loan providers (alternative financial solution [AFS] services), such as for example payday loan providers and vehicle name loan providers.

The degree that borrower situations that are financial be produced worse through the usage of high priced credit or from restricted usage of credit was commonly debated. Customer teams frequently raise issues about the affordability of small-dollar loans. Continue reading