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Jun 5, 2008 Payday loans can be bad news and have been known to reach upwards of 700+% APR. We talk about 43 comments | Comment on this Article. Twitter So rather than get hit with late fees or hurt his credit any worse than it already is, Jim decides to seek out what is known as a payday loan. He figures Check out this page for insightful news articles and blog posts that are related to the direct lender payday loans industry.The ads are on the radio, television, the Internet, even in the mail. They refer to payday loans, cash advance loans, check advance loans, post-dated check loans, or deferred deposit loans. The Federal Trade Commission, the nation's consumer protection agency, says that regardless of their name, these small, short-term, cash loans miami fl Mar 30, 2018 A payday loan business in Phoenix. Payday lenders—those usurious operations that profit from providing high-interest loans to working-class and poor Americans—have seen their prospects improve dramatically under the Trump administration and the Republican Congress. A joint resolution introduced
Jul 16, 2013 Payday loan companies have a new debt-collection tool: Texas courts and prosecutors. best fast cash options Feb 22, 2013 Legislators need to cast aside politics and self interest to address the growing problems that the payday and auto title loans are creating for Texas consumers. Several cities, including San Antonio, have established tougher rules on payday loans because state lawmakers have failed to do so. According to May 29, 2015 For people who need money quickly but don't have good credit, payday lending is a viable but extremely costly option to obtain quick cash for sudden expenses. Fortunately, high-cost payday lending may not be the only option available to you. Thanks to a program from the National Credit Union Article Image. The Consumer Financial Protection Bureau (CFPB) made a bold move in proposing new rules that would help prevent individuals who use short-term lending services from falling into so-called “debt traps.” Often what happens with short-term lending services (sometimes known as “payday” loans) is that
Jan 17, 2018 This study discusses regulatory options that federal and state legislatures might consider for the payday loan industry. These options include outright prohibition; restricting the implicit annual percentage interest rate; limiting the amount per loan; limiting the number of concurrent loans; setting lower and best online payday loans yahoo answers Mar 29, 2016 Articles. American Banker. “How can we replace a two-week loan model at a better cost?” said David Rothstein, the chair of the Coalition for Safe Loan Alternatives, a new group formed to offer payday lending alternatives. With the Consumer Financial Protection Bureau expected soon to roll out a proposal Oct 5, 2017 Federal regulators issued new rules on Thursday that will drastically rein in access to payday loans and restrict certain practices that have drawn ire from consumer advocates. Payday loans, which provide strapped consumers with quick access to cash, are typically characterized by their ultra-high interest Article — From the April 2009 issue. Usury Country. Welcome to the birthplace of payday lending One of the inventors of payday lending—the business of making small, short-term loans from retail locations at steep rates—Eaton operates out of a converted service station, with a tarp sign in red and white: here's where it
Learn from First Federal Bank about payday lending and alternative financial options to a payday loan. cash advances az May 10, 2013 Letters to the Editor The New York Times 620 Eighth Avenue New York, NY 10018. Re: A response to your editorial on payday lending. My name is Tim Ranney and I am the president of Clarity Services, a leading credit bureau in the non-prime credit services industry. I wanted to offer a few thoughts on 13 hours ago Maranda Brooks stands outside a payday loans business that she frequented in the past Thursday, Jan. 22, 2015, in Cleveland. Troubled by consumer complaints and loopholes in state laws, federal regulators are putting together expansive, first-ever rules on payday loans aimed at helping cash-strapped Nov 17, 2017 Payday lending is not something you'd think a major Democratic politician would want to boost. But Sen. Mark Warner (D-Va.) has gotten himself into some hot water over a bill that critics say would do exactly that. Payday lenders and their ilk have come under increased scrutiny recently for offering poor
How Does Payday Loan Consolidation Work? | LendingTree
Oct 5, 2017 A tough new rule laid out by federal regulators Thursday will make payday loans and other types of high-risk borrowing safer for consumers. The.Jan 22, 2018 For financially vulnerable people who are turned down for bank loans, payday loans can be a last resort to get money to pay for bills and essentials. And that makes The CFPB reports payday loans typically have an APR of 400%, though it can be much higher. “It may seem Article preview thumbnail Mar 5, 2010 Deferred deposit loans, commonly known as "payday loans" (also called cash advance loans, check advance loans and post-dated check loans), have become an increasingly popular method for consumers to access fast cash. How it works. Bad credit? No credit? Not a problem. All a consumer needs to Jun 20, 2015 JACKSON, Miss. — To drive down Ellis Avenue, just off the interstate, is to visit a paradise of easy money. Along a four-block drag of fast food joints and half-empty strip malls, the payday lenders are packed in tight. The names on their fluorescent signs melt into one another: Paycheck Loans, Advance Feb 15, 2018 Once you factor in the amount you need, how soon you need it, and your credit score, you'll narrow down your options. If you need a large sum in a short amount of time and don't have good credit, you may only qualify for an installment loan or a payday loan. In this article, we break down what each loan is
Jun 15, 2016 The federal watchdog agency for consumer financial products just released a draft of national rules for the payday lending industry. In most states, these rules are a welcome first step toward reining in payday lenders, whose business model involves charging an average of 300% annual interest, mainly to FIND MORE LEGAL ARTICLES. Search. Over the last few years, establishments known for their payday loan services have popped up on seemingly every street corner. With promises of helping the cash strapped get by until payday, these businesses seem imminently helpful. That is, until one reads the fine print and Feb 3, 2017 Publication of information on an FCA-authorised payday loan price comparison websites (Part 3). Article 4.1. The 'Obligation to Publish Date' is 26 May 2017. Article 10. Online lenders must notify the CMA about their engagement with price comparison websites (PCWs) as soon as reasonably practicable, Mar 26, 2015 The Consumer Financial Protection Bureau is readying new regulations on payday loans and other high-cost forms of credit. Officials with the agency say the loans can trap borrowers in a cycle of debt. Mar 8, 2018 People who take out payday loans would have more time to pay them off under a bill that passed the Alabama Senate today, a change that would effectively reduce the triple-digit interest rates borrowers pay. Advocates for payday loan reforms say the high cost of the loans helps keep borrowers in debt.
Payday Loans. Payday loan companies offer “cash back on your check.” Customers write a personal check payable to the lender for the amount of cash they need plus a fee. The company .. million paid circulation, regularly carries articles on health, product safety, marketplace economics and legislative, judicial, and.Mar 13, 2017 Getting all your financial trains to run on time is hard. You get the raise to cover rent and pay down those credit cards — but then there's taxes and your student loans and insurance. Don't have a fully stocked emergency fund? One bad break like a job loss or a medical emergency, and you'll go off the rails. Nov 12, 2017 Nobody likes being in debt, but it's even worse when it seems like there's no way out. You don't have to be stuck in the payday loan debt cycle forever.Feb 23, 2018 Elizabeth Warren and Acting CFPB Director Mick Mulvaney have different views on payday lending and mandatory arbitration. The driving force behind the creation of the Consumer Financial Protection Bureau and the person revamping that institution right now traded barbs in a series of letters on payday Nov 25, 2012 The highly political intervention by Justin Welby, the Bishop of Durham, is his first since being announced as the successor to Dr Rowan Williams as leader of the Church of England. Bishop Welby has denounced payday loan firms and the levels of interest they charge as “morally wrong” and even a “sin”.
Nov 1, 2015 Payday loans are a costly way for consumers to borrow money and many states have laws banning or restricting their use. This article describes how payday loans operate, their extremely high cost for borrowers, and results of a study that examined potential effects of payday loan usage and state payday Predatory Loans: Payday and Car Loans In other areas where members of Congress have refused to act when the public is financially victimized is in the predatory payday and car loans. An article in Newsweek (May 7, 2007) described how interest rates could exceed 700 percent, resulting in a debt trap. In payday loans Sep 24, 2016 A profitable industry naturally attracts competition. One previously shadowy corner of personal finance, payday loans, is starting to feel the heat from some unexpected sources. The frustration of industry critics over regulators' inability thus far to rein in what they view as the predatory products has attracted Oct 30, 2017 New rules from the Consumer Financial Protection Bureau could reduce “payday” lending by as much as 66 percent, writes Paso Robles columnist Phil Dirkx. The Tribune article said a bureau of the federal government has “finalized” some new rules to reduce the “payday” lenders' outrageous charges. Oct 21, 2011 Complaints against payday and other high-interest small lenders nearly doubled in New Hampshire after they were effectively banned from the state in July 2010 -- a statistic that supporters seized on Wednesday in moving forward a bill that would bring the industry number of complaints against
Payday Loans | Alternative Lending | First Federal Bank
Mar 7, 2017 For many Oklahomans in a financial trouble, payday loans can seem like a quick and easy fix. Borrowers can take out a payday loan for up to $500, secured by a post-dated check, usually for a period of 12 to 14 days. Under Oklahoma's deferred deposit lending act, payday lenders can charge $45 in fees are exorbitant because it would cost thousands of dollars to take a cab across the country. Moreover, the short-term alternatives to payday loans may prove even more costly. A May 2005. Consumer Reports article revealed that the implicit APR on overdraft protection ranged from 608 percent to 791 percent. Bounced check “Before you continue reading this post you need to be aware that the case study presents actual data and results from Google. We do not endorse using these kind of black hat practices. We only present them as they are being used and abused. Maybe Google will fix these faster. All for the sake of search transparency … “.Oct 5, 2010 Roughly 20 years ago, during the administration of President George H.W. Bush, I wrote a news article for the Wall Street Journal about the federal government's plans (later codified in legislation during the Clinton administration) to distribute food stamps and other government benefits electronically. Apr 19, 2017 The check-cashing and payday lending industries have long been marked for reforms because of the high interest rates they charge the working poor. But now even the middle class — college graduates who work and own homes — have trouble making ends meet and thus are taking out high-interest
Oct 5, 2017 WASHINGTON (Reuters) - Revenues for the $6 billion payday loan industry will shrivel under a new U.S. rule restricting lenders' ability to profit from high-interest, short-term loans, and much of the business could move to small banks, according to the country's consumer financial watchdog. A money Oct 9, 2017 Payday lenders and their allies in Congress will have a hard time defending the loans that the Consumer Financial Protection Bureau seeks to outlaw in its new rules for payday and car title loans. That's because the rules are tightly focused on averting debt traps. I. Introduction and Summary. In recent years, regulators and researchers have focused considerable attention on. “payday loans,” small, single-payment loans carrying substantial fees. These loans are advanced to people with steady incomes against a post-dated check which the lender can cash on the borrower's next Sep 25, 2013 On July 3rd, was penalized by the payday loan update, which resulted in a 81% loss in organic traffic. This blog explains how, within three weeks, we Website directories; Article marketing; Paid links; Thin content; Keyword stuffing; Duplicate content. With techniques like these, it was only a Apr 13, 2017 Lisa Servon: It's actually just payday lenders, right? Todd Krainin: Right. Lisa Servon: Not even counting the check cashers, and that's an important difference because, in 13 states, payday lending is illegal. Todd Krainin: That speaks to some incredible need for this, what you call, alternative banking
Oct 19, 2015 Except for the ten to twelve million people who use them every year, just about everybody hates payday loans.Discover what's behind the uptick in payday loans for millennials as reported in recent studies. What does it mean for them, and for the rest of us? Mar 1, 2018 On February 27, the U.S. Court of Appeals for the 3rd Circuit held that an arbitration clause is unenforceable if the corresponding forum selection provision designates a forum that does not actually exist. According to the opinion, in 2012 the plaintiff obtained a $5,000 loan from the defendant, an online loan Dec 1, 2017 Congress has it in for consumer protections enacted by the Consumer Financial Protection Bureau. A congressional resolution introduced Friday in the House would kill the CFPB's new rule aimed at making sure borrowers of so-called payday loans can afford to repay their debt. The House measure's 3/23/2018. article Trump official quietly drops payday loan collector case and considers spiking others: Sources. (Washington D.C.) -- The top cop for U.S. consumer finance has decided not to sue a payday loan collector and is weighing whether to drop cases against three payday TAGS: Native News · Legal & Courts
Jan 20, 2016 That quick-fix payday loan can easily turn into a constant and unsustainable burden before you know it. But that doesn't mean all short-term loans will bankrupt you. If you're a cautious and diligent borrower, a short-term loan could be just what you need to push your small business in the right direction.This paper proposes a model to examine the effect of unsecured payday loans to financial distress of low-income households and aims to open a discussion within academics and government on this topic. The theoretical model is based on the evidence from the. British Household Panel Survey and interviews done by Feb 14, 2017 To Tylor Johnson, it looked like the deal of a lifetime. The Colorado-based debt broker had been angling for years to buy a debt portfolio from Scott Tucker. In the world of payday loans, Tucker was King Kong. He had pioneered an entire industry — one sturdily rooted in the Kansas City area — by using the Jan 3, 2018 INDIANAPOLIS-- Changes could be coming to the payday lending industry in Indiana. State Sen. Greg Walker (R-Columbus) filed on Tuesday the first of its kind legislation that would cap small loan finance charges at 36 percent. Currently, the cap for payday loans in Indiana is 391 percent, according to Aug 29, 2017 The final payday lending rules are coming, but reporting by The Wall Street Journal over the weekend suggests that they may not take quite the toll on the lending industry as once thought. The Consumer Financial Protection Bureau (CFPB), it seems, is considering proposals that would scale back the rule's
Apr 30, 2015 Related article: A new payday loan alternative · New Ways for Employers To Make Affordable Payday Loans to Workers. TRANSCRIPT: The federal government right now through the Financial Protection bureau is trying to write rules governing payday loans. Payday loans are loans where even if you don't Oct 6, 2017 Payday lenders in Nebraska and 34 other states where short-term, small-dollar loans are permitted eventually will have to take extra care to establish borrowers' ability to repay before the loans. Nov 29, 2017 A number of Ohio lawmakers say they recognize the need to change Ohio's failed payday lending law, but questions remain about what steps they are willing to support. No payday lenders in Ohio are registered under the Short Term Loan Act that lawmakers approved and voters overwhelmingly upheld in A payday loan is a type of short-term borrowing where a lender will extend high interest credit based on a borrower's income and credit profile. A payday loan's principal is typically a portion of a borrower's next paycheck. These loans charge high interest rates for short-term immediate credit. These loans are also called cash If you are going through tough circumstances, payday loans may sound a tempting option to you. But if you are not an experienced person, we suggest that you consider this option after a lot of thinking. Since these loans feature a very high interest rate, they shouldn't be taken unless you have no other option. Below are 7
The controversy around Mark Warner's payday lending bill, explained
Dec 21, 2015 This is an archived article that was published on in 2015, and information in the article may be outdated. It is provided only for personal research purposes and may not be reprinted. Herman Diaz of South Salt Lake borrowed his first payday loan — at about 500 percent annual interest — because Sep 5, 2008 The Fiscal 2007 Military Authorization Act made it illegal for creditors to grant payday loans and car title loans to military members due to abuses existing in the industry. In the past, some military members have paid up to 800 percent interest at payday, Jan 16, 2018 The U.S. Consumer Financial Protection Bureau said on Tuesday that it intends to reconsider a recent rule that would significantly curb payday lending. The rule, finalized in October under Obama appointee Richard Cordray and set to begin taking effect this year, would require lenders to determine if Dec 23, 2017 Download citation | A Comparative Analys | "One of the most rapidly growing and controversial forms of consumer lending to recently emerge in the marketplace has been payday advances. of Payday Loan Customers. Article in Contemporary Economic Policy 26(2):299-316 · April 2008 with 506 Reads. Oct 30, 2011 High Interest Loans and Class loans.2 What would you expect the general demographic characteristics of the payday and title loan users to be? Would they be primarily middle-income Americans or people closer to the poverty level? Would they be primarily homeowners or renters? This article describes
Article 2. Payday Loans. (Source: P.A. 94-13, eff. 12-6-05.) a new installment payday loan one time during the term of the initial loan; provided that the total duration of indebtedness on the initial installment payday loan combined with the total term of indebtedness of the new loan refinancing that initial loan, shall not Before you sign up for a payday loan, you need to consider other options because payday loans can actually be very bad debt traps that will lead you into further debt. . Being able to pay off your loan quickly goes back to Part 1 of this article—you must make sure to create a budget for yourself and spend your money wisely Oct 23, 2017 CUNA's Final Rule Analysis of the Consumer Financial Protection Bureau's (CFPB) short-term, small-dollar loan rule is now available. CUNA prepared the analysis so credit unions can start to digest the rule and figure out how it will affect small-dollar lending at their institution. The rule was finalized Oct. 4, Apr 14, 2018 Opponents of the payday lending industry in Ohio have been waiting a long time for regulatory reform. To the dismay of groups like Ohioans for Payday Loan Reform — which want a strict 28% cap on interest rates and the closing of loopholes that allow payday lenders to charge a series of fees that amount May 4, 2017 For the past three years, one University of Minnesota student has battled payday lending. Adam Rao, a graduating MBA candidate at the Carlson School of Management, has worked with two different companies to help those effected by payday lending, a formof high-interest, short-term money lending.
News about Payday Loans, including commentary and archival articles published in The New York Times. Latest; Search. Search. Clear this text input. Latest Articles. When Bail Feels Less Like Freedom, More Like Extortion. As bail has grown into a $2 billion industry, bond agents have become the payday lenders of the Nov 29, 2017 The loan sharks smell blood. A payday lender selling loans derided as “debt traps” by the Consumer Financial Protection Bureau is going public — and Oct 5, 2017 New federal rules on payday lending were finalized on Wednesday. The new rules, first proposed by the Consumer Financial Protection Bureau last year, will go into effect 21 months after they are published in the federal register. Payday loans are usually around $500, and come with fees and interest rates of Law, Professor Mark Loewenstein of the University of Colorado School of Law, and. University of New Mexico School of Law alumnus Justin Breen for their comments on earlier drafts of this article. 1. See Mark Flannery & Katherine Samolyk, Payday Lending: Do the Costs. Jutify the Price? 1 (FDIC Center for Financial Nov 24, 2016 Payday loans are perhaps the most hotly debated topic in the area of consumer financial services today. These small (typically under $500), unsecured, short-term (two to four week) loans have generated concern from policymakers and consumer advocates primarily because of their high cost and the fact
Sep 24, 2013 SAN FRANCISCO, September 24, 2013 /PRNewswire/ -- California Payday Loan Laws Explained in New Article by Consumer finance siteOct 6, 2017 Payday and car-title lenders must now check a borrower's ability to repay before issuing a loan. Payday loan consolidation: Ends multiple pdl debts and saves money. Article; Ask Questions; Related Articles. How does payday loan consolidation work? What will be your new monthly payment? Payday loan debt consolidation pros and cons; Why consolidation program is the best payday loan debt solution; Compare pdl A. A Payday Lender and a Borrower may agree to a payment plan for a Payday Loan at any time. B. A Payday Lender shall disclose to each Borrower that a payment plan described in this section is available to the Borrower after the maximum amount of renewals allowed by state law. The Payday Lender shall disclose this Apr 19, 2011 When borrowing money, it is important to consider your options carefully. A payday loan can appear quite attractive on the surface. Payday loans are quick and easy and you get the cash you need. You don't have to risk being turned down or lectured about emergency savings. You can even get service
Mar 6, 2018 Payday loans are short-term loans that are often used to get through a rough spot. Unfortunately, there are very few situations in which these loans actually end up being helpful. Before you use one, make sure you understand the costs and risks. This page gives you a quick overview of how payday loans 5 days ago The popular progressive idea of using the United States Postal Service to help families struggling with their finances escape the trap of predatory payday lending got a renewed bounce this week from a prominent senator widely expected to run for the White House in 2020. Sen. Kirsten Gillibrand's (D-NY) Feb 1, 2018 The Indiana House on Wednesday evening voted to approve a bill favored by the payday loan industry that advocates say would allow people with poor credit scores secure longer-term, higher-value loans than is typical for the industry. House Bill 1319 was opposed by veteran groups, religious institutions Feb 10, 2016 Back in June 2014, Consumerist showed readers what might have been the scammiest payday loan we'd ever seen. Today, federal authorities arrested the man behind the company, AMG Services — along with his lawyer and another, unrelated, payday lender — for allegedly running online payday The cost of borrowed funds was a relatively unimportant component of costs at Article 3.16 lenders, because most of the lending capital was from owners' resources. Payday Loans A payday loan is a small, short-term, single-payment consumer loan (discussed further in chapter 8). For this type of credit, the customer writes a
To cope with this need, millions choose to take out payday loans. Often the subject of controversy and criticism, these loans have become a mainstream credit option, considered by consumers alongside so-called “traditional” credit products offered by banks and credit unions. This article examines the issues surrounding Article 13. 2001. From Checks to Cash: The Regulation of the. Payday Lending Industry. Scott Andrew Schaaf. Follow this and additional works at: Part of the Banking and Finance Law Commons. This Comments is brought to you for free and open access by Carolina Law Scholarship Mar 27, 2018 Durbin, Democratic Senators Warn CFPB Against Repeal Of Rule Cracking Down On Predatory Payday Lending Schemes. WASHINGTON, D.C. – Today, U.S. Senate Democratic Whip Dick Durbin (D-IL) and 42 of his Senate colleagues sent a letter to Consumer Financial Protection Bureau (CFPB) Acting If you have an emergency and you are in between paychecks, then you should consider fast payroll loans. There are payday loan providers who offer quick cash to people in need. The payday loan companies are set up online, so that anyone can fill out an application, from the comfort and privacy of their home. One can Mar 29, 2018 The CFPB recently dropped a case against a payday loan collector previously charged by the bureau for wrongfully collecting fees. Credit Adjusters mistakenly collected about $50 million, and approximately $45 million of that was slated to be returned, according to unnamed sources in the CNBC article.
Payday lending is declining - Consumer loans - The Economist
Oct 5, 2017 The rules announced by the agency, the Consumer Financial Protection Bureau, are likely to sharply curtail the use of payday loans, which critics say prey . A version of this article appears in print on October 6, 2017, on Page B1 of the New York edition with the headline: Payday Lenders Face Tough New framework of tribal sovereign immunity. Namely, the lending operations executed by the Miami Tribe of Oklahoma serve as an example of a tribally run business entitled to sovereign immunity. This article begins with an exploration of the payday lending industry and the payday loan itself, emphasizing the arguments for and. Original Articles Payday lending – the selling of high-interest, short-term credit – has thrived following the decline of the traditional high street banking system and the reluctance KEYWORDS: Payday lending/borrowing, Wonga, multimodality, multimodal critical discourse analysis, online advertising, the fringe economy Feb 20, 2013 Each year, nearly 12 million borrowers take out payday loans. Yet, only 14% can afford to repay what they owe without taking on more debt, according to a recent report from Pew Charitable Trusts. Sep 27, 2017 Sweeping new federal rules aimed at curbing payday loans are to be released in the coming days. But backers of the crackdown say states need to remain vigilant. The new rules proposed by the Consumer Finance Protection Bureau are expected to require lenders to verify key information from
Apr 8, 2017 In Missouri, home of some of the most relaxed consumer lending laws in the nation, the payday loan industry has been shrinking for years. After the Legislature changed the state's usury laws to allow high-interest, short term loans in the 1990s, storefronts began popping up across the state. By 2005, there Payday loans seem enticing when you encounter a situation when money is needed immediately; however, there are a number of dangers that should be considered prior to applying for one. Before taking out a payday loan, we urge you to not only read this article, but to do much more research on your own. Article May 28, 2015 One industry that frequently takes advantage of the poor and others in financial distress is payday lending. Payday lending (also known as payday loans) is the term used to describe the practice of lending small amounts of money to people, usually $350 or less, for two week periods, i.e., until their Jul 11, 2017 Seniors, many of whom are living on fixed incomes, are now the largest group of payday loan borrowers in California, according to the report. Californians 62 and older accounted for 23.4 percent of the 2016 total, and they took out nearly 2.7 million loans, a nearly three-fold increase from the previous year. Feb 4, 2018 Payday lenders fear that a new federal rule will nearly eliminate their main product: the small, single-payment loan. The Consumer Financial Protection Bureau has proposed a rule that could restrict loans to people who take out too many.
It's easy to get a payday loan, but they can cost you a lot of money. Learn how they work and what to watch out for.Payday loans videos and latest news articles; your source for the latest news on Payday loans . Sep 19, 2016 If the critics of payday lending are correct, we should see an increase (decrease) in signs of financial distress after the legalization (prohibition) of payday lending, and these changes should be more pronounced in areas with large military or minority populations. This article uses county-level data to test this Nov 29, 2017 Among other requirements, House Bill 347 caps rates for most small loans at 175 percent — still much higher than the 36 percent some legislators proposed — and requires that short-term loans are repayable in at least four installments rather than all at once, effectively ending payday loans. Consumer Jul 26, 2011 Lenders who make these loans charge interest rates and fees so high that when they hear the details, most Americans insist that the loans must be illegal. This article briefly describes the history of the CFPB, describes payday and title loan products and their customers, describes the CFPB's general