BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1158
                                                                  Page  1

          Date of Hearing:   April 25, 2011

                      ASSEMBLY COMMITTEE ON BANKING AND FINANCE
                                   Mike Eng, Chair
                   AB 1158 (Calderon) - As Amended:  April 13, 2011
           
          SUBJECT  :   Deferred Deposit Transactions.

           SUMMARY  :   Changes the California Deferred Deposit Transaction 
          Law (CDDTL) to allow a licensee to defer the deposit of a 
          customer's check with a face amount of $500, up from $300.

           EXISTING LAW  

          1)Establishes the CDDTL (also known as the Payday Loan Law, 
            Financial Code Section 23000 et seq.).  The CDDTL:

             a)   Applies to any person that makes a transaction in which 
               the payday lender defers depositing a customer's personal 
               check until a specific date, pursuant to a  written 
               agreement;

             b)   Does not apply to a state- or federally-chartered bank, 
               thrift, savings association, or industrial loan company;

             c)   Requires applicants who wish to become payday lenders to 
               submit an application for each location, an application fee 
               of $200, and to submit to various other requirements 
               including a background check, and prohibits anyone from 
               engaging in the business of payday lending without a 
               license from the Department of Corporations (DOC); 

             d)   Allows lenders to defer the deposit of a customer's 
               personal check for up to 31 days; limits the maximum value 
               of the check to $300; limits the maximum fee to 15%  of the 
               face amount of the check; and requires payday lenders to 
               distribute a notice to customers prior to entering into any 
               payday loan transaction that includes information about the 
               loan and loan charges and a listing of the borrower's 
               rights;

             e)   Requires each payday loan agreement to be in writing in 
               a type size of 10 point or greater, written in the same 
               language that is used to advertise and negotiate the loan, 
               signed by both the borrower and the lender's 








                                                                  AB 1158
                                                                  Page  2

               representative, and provided by the lender to the borrower, 
               as specified; 

             f)   Allows payday lenders to grant borrowers an extension of 
               time or a payment plan to repay an existing payday loan, 
               but prohibits the lender from charging any additional fee 
               in connection with the extension or payment plan;

             g)   Requires each licensee to maintain a net worth of at 
               least $25,000 at all times; and,

             h)   Prohibits payday lenders from entering into a payday 
               loan with a customer who already has a payday loan 
               outstanding, and from doing any of the following:

               i)     Accepting or using the same check for a subsequent 
                 transaction;

               ii)          Permitting a customer to pay off all or a 
                 portion of one payday loan with the proceeds of  another;

               iii)         Entering into a deferred deposit transaction 
                 (DDT) with a person lacking the capacity to contract;

               iv)          Accepting any collateral or making any payday 
                 loan contingent on the purchase of insurance or any other 
                 goods or services;

               v)     Altering the date or any other information on a 
                 check, accepting more than one check for a single payday 
                 loan, or taking any check on which blanks are left to be 
                 filled in after execution;

               vi)          Engaging in any unfair, unlawful, or deceptive 
                 conduct or making any statement that is likely to mislead 
                 in connection with the business of DDTs; or,

               vii)         Offering, arranging, acting as an agent for, 
                 or assisting a deferred deposit originator in  any way in 
                 the making of a DDT unless the deferred deposit 
                 originator complies with all applicable federal and state 
                 laws and regulations.

          2)Provides that licensees who violates the payday loan law are 
            subject to suspension or revocation of their licenses, and 








                                                                  AB 1158
                                                                  Page  3

            that violations of the payday loan law are subject to civil 
            penalties of $2,500 per violation;

          3)Specifies that anyone that violates any provision of Section 
            670 of the John Warner National Defense Authorization Act for 
            Fiscal Year 2007 (Public Law 109-364) or any provision of 
            Section 232 of Title 32 of the Code of Federal Regulations, as 
            published on August 31, 2007, in Volume 72 of the Federal 
            Register, violates the California payday loan law.  �Financial 
            Code, Section 22345]

          4)Provides that a person that refuses to offer a payday to a 
            member of the military is not in violation of the Military and 
            Veterans Code provision relating to discrimination against 
            members of the military.  �Financial Code, Section 23038].

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

          Need for the bill:

          According to information provided by the author:

               California is currently tied for the lowest maximum loan 
               limit in the country even with a higher cost of living than 
               anywhere else. In 2007, the Department of Corporations 
               delivered a report titled "The California Deferred Deposit 
               Transactions Law' to the Legislature. One of the key 
               recommendations of the report was to increase the maximum 
               loan amount to $500 or $750 . They based this on the fact 
               that California was low compared to other states and that 
               it appeared too low to meet the need for an emergency for 
               consumers. Taking account of inflation since 1995, an 
               inflation adjusted maximum loan limit at the end of 2010, 
               comparable to $300 in 1995 would be $442.05. This 
               calculation was performed using the Annual California 
               Consumer Price Index for All Urban Consumers. 

           Payday Lending Background  :

          A payday loan, known more formally in California as a DDT, is a 
          short-term loan in which a borrower writes a post-dated, 
          personal check to a lender for a specified amount, which is 
          capped by law.  The date on the check is the date on which the 








                                                                  AB 1158
                                                                  Page  4

          parties agree that the borrower will repay the loan.  The lender 
          advances the borrower the amount on the check, less the fee, 
          which is also capped by law.  The lender does not cash the check 
          at the time the loan is made.  Both parties are aware that the 
          borrower lacks sufficient funds to cover the check when the 
          check is written.  The assumption underlying the loan is that 
          the borrower will repay the loan by the agreed-upon date, either 
          by depositing sufficient funds in his or her checking account to 
          cover the check, or by paying the lender in cash on the loan's 
          due date, and having the lender return the original check to the 
          borrower, without cashing it.  

          California enacted its earliest version of a payday lending law 
          in 1996, and gave jurisdiction over payday lenders to the 
          Department of Justice (DOJ) SB 1959, (Calderon, Chapter 682, 
          Statutes of 1996).  SB 898 (Perata, Chapter 777, Statutes of 
          2002), enacted the CDDTL; and shifted the responsibility for 
          administering payday lending from DOJ to the DOC.  

          Under the CDDTL, any lender who makes a payday loan must be 
          licensed.  Each licensee may defer the deposit of a customer's 
          personal check for up to 31 days.  The face amount of the check 
          presented by a borrower may not exceed $300, and the fee charged 
          by the licensee may not exceed 15% of the face amount of the 
          check ($45 on a $300 check).  Licensees may charge one 
          non-sufficient funds fee, capped at $15, for checks that are 
          returned by a customer's bank.  Licensees may not directly, or 
          indirectly charge any additional fees in conjunction with a 
          payday loan.  Licensees may not enter into a payday loan with a 
          customer who already has a payday loan outstanding and may not 
          allow a customer to use one loan to pay off another.  Licensees 
          are also forbidden from accepting any collateral for a payday 
          loan or making any payday loan contingent on the purchase of any 
          goods of services.  Each payday loan must be made pursuant to a 
          written agreement.  Licensees must post their fees and charges 
          prominently at their business locations.
           
           On March 10, 2008, the DOC released two reports to fulfill its 
          requirements under Section 23057 of the Financial Code.  The two 
          reports are titled, "California Deferred Deposit Transaction 
          Law, California Department of Corporations, December 2007" (DOC 
          report) and "2007 Department of Corporations Payday Loan Study, 
          December 2007, submitted to the California Department of 
          Corporations by Applied Management Planning Group, in 
          conjunction with Analytic Focus" (AMPG report).  








                                                                 AB 1158
                                                                  Page  5

          
          The key findings from the aforementioned reports:

           California is home to 447 licensed payday lenders, which 
            operate 2,403 licensed payday lending stores.  A total of 338 
            licensees indicated to AMPG that they were actively making 
            loans during the study period of April 15, 2006 through 
            September 11, 2007.  (Note:  new data from the 2009 Annual 
            Report, Operation of Deferred Deposit Originators Under the 
            California Deferred Deposit Transaction Law, reveals the 
            existence of 2,187 locations)

           Over two-thirds of all payday loans are made by only twelve 
            licensees (AMPG).  The largest 30 licensees made 82% of payday 
            loans by dollar volume during 2006 (DOC).

           Over 61% of all licensees operate only one payday loan 
            location (AMPG).

           Forty-nine of the state's 58 counties have at least one payday 
            loan location.  With 166 payday loan locations, the City of 
            Los Angeles has the highest concentration of payday loan 
            locations of any city in the state.  The City of Sacramento is 
            second, with 81 locations (AMPG).

           Sixteen licensees (3.5%) reported making over 115,000 payday 
            loans over the Internet during 2006 (DOC).  

           The average length of a payday loan is 16 days (DOC).

           Most payday lenders advertise using large, conspicuous signage 
            on the outsides of their licensed locations (DOC).  Many (70%) 
            also advertise in local telephone directories; a smaller 
            percentage advertise in local newspapers (29%) and Internet 
            directories (27%; AMPG).

           Before agreeing to lend to a borrower, most licensees require 
            the borrower to provide identification, proof of some form of 
            income, a home address, employer's address, and checking 
            account information.  Licensees rarely conduct a credit check 
            or verify whether the borrower has the ability to repay the 
            loan, when their other debts and expenses are considered.  
            Most payday loans can be obtained in under 15 minutes (DOC).

           Most lenders accept any kind of verifiable income as proof of 








                                                                  AB 1158
                                                                  Page  6

            income, other than unemployment checks or reports of 
            self-employment (AMPG).  Payroll checks, government assistance 
            checks, retirement checks, disability checks, annuity and/or 
            structured settlement checks are the most common forms of 
            income verification accepted.  Although all payday loan 
            customers are required to have and show proof of an active 
            checking account, only 5% of licensees require that borrowers 
            have the qualifying income deposited directly into their 
            checking accounts (AMPG). 

           Cash is the most common method of distributing loan proceeds 
            to borrowers, although the option of electronically depositing 
            the funds into customers' bank accounts is increasing in 
            popularity among licensees (DOC).

           Eighty four percent of licensees' business is attributable to 
            repeat customers (only sixteen percent comes from customers 
            who take out only one loan).  Nineteen percent of licensees' 
            business is attributable to customers who took out more than 
            15 loans during the 18-month period studied by AMPG.  

           Forty one percent of licensees offer some type of bonus 
            (either cash or gifts) to customers who refer new business to 
            the licensees.  Cash is much more common than other types of 
            gifts.  Of those who offer cash bonuses, nearly one half offer 
            $10 or less, and just under one third offer between $20 and 
            $25 (AMPG).

           Very few licensees accept personal checks for repayment (this 
            despite the fact that a post-dated check is required in order 
            to obtain a payday loan).  Customers commonly pay off their 
            loans in cash.   Nearly all lenders who do accept personal 
            checks for repayment charge non-sufficient funds (NSF) fees 
            for returned checks (DOC and AMPG).

           Fifty seven percent of licensees require customers to borrow 
            at least $50.  The majority of loans (63%) are between $200 
            and $255.  Twenty lenders responded that the minimum amount 
            they would lend was $255 (AMPG).

           Although lenders may charge up to $45 in loan fees to lend the 
            maximum amount of $300, 14% of lenders charge less than $45 on 
            $300 loans.  The smallest amount charged on a $300 loan was 
            $25, corresponding to a maximum loan amount of $275 (AMPG).









                                                                  AB 1158
                                                                  Page  7

           To prevent the loss of revenue due to defaulted loans, most 
            lenders (87%) offer arrangements in which borrowers are 
            allowed to pay back loans at a reduced rate or based on an 
            agreed-upon schedule.  Lenders reported that about 20% of 
            loans issued during the eighteen-month study period required 
            some type of workout arrangement (AMPG).  However, less than 
            1% of all payday loan customers entered into formal, written 
            payment plan arrangements during 2006 (DOC).  

           Customers who take out multiple loans in a year tend to do so 
            in a consecutive fashion (with less than five days elapsing 
            between paying the first one off and obtaining a second one). 

           Nearly 450,000 borrowers had back-to-back time-frames of 6 
            loans or more. (DOC)

           More than 57,147 borrowers had more than 19 consecutive 
            transactions during 2006 accounting for only 4% of borrowers, 
            but for 50% of the loans. 

           Of those borrowers who obtained more than one payday loan in 
            the last eighteen months, 28% used multiple locations of the 
            same payday lender; 72% used multiple lenders (AMPG).

           Borrowers were asked whether the amount borrowed was the 
            amount needed or the most the lender would loan.  When asked 
            in this way, 63% of borrowers said they borrowed the amount 
            needed; 32% said they would have borrowed more, but the lender 
            wouldn't loan it; and only 3% said that the lender offered 
            more than the borrower needed.

           When borrowers were asked where they obtained the rest of the 
            money they needed if they could not obtain all they needed 
            from the payday lender, 8% said they borrowed the money from 
            family or friends, 8% said they did not get the rest of the 
            money they needed, 5% waited until their next payday, 3% went 
            to another payday lender, and less than 1% borrowed money from 
            a bank.  

           Thirty-six percent of borrowers indicated they had used more 
            than one payday lender.  When asked why, 73% said they needed 
            more money than one location would loan them at one time, 12% 
            said they needed more money before the loan with the first 
            company could be paid off, and 11% said they used one loan to 
            pay off another.  








                                                                  AB 1158
                                                                  Page  8


           Report policy recommendations.
           
          1)Clarify and confirm that licensees cannot refer delinquent 
            payday loans to a local prosecutor for collection of returned 
            checks
           
          2)Enhance the regulation of electronic transactions.  

          3)Improve consumer disclosures by requiring that the notice 
            provided to borrowers prior to entering into a payday loan 
            agreement be a separate, distinct document from the written 
            agreement; require the licensee to have the borrower initial a 
            copy of the notice to acknowledge receipt; and require the 
            licensee to retain a copy of the notice with the borrower's 
            initials acknowledging receipt in the file.  

          4)Require license applicants and existing licensees to notify 
            DOC of other business that would be or is being conducted at 
            the licensed location.  

          5)Expand consumer protections for payday lending conducted over 
            the Internet by  requiring that notices and disclosures are 
            provided to Internet borrowers, and that borrowers can 
            download the agreement, notices, and disclosures.  
            Alternately, if the borrower cannot download those documents, 
            require the licensee to mail copies to the borrower within 24 
            hours.  

          6)Require that payment plans entered into between licensees and 
            borrowers specify the payment dates and amounts of each 
            payment, be in writing, and be signed by the borrower.  

          7)Require a written agreement signed by the borrower in order to 
            extend the due date of a loan.  Provide the licensee with an 
            option to notify the borrower by mail of the approval to 
            extend the due date of the loan, if the borrower elects not to 
            sign the extension agreement.  Like the recommendation above, 
            this recommendation would help avoid misunderstandings between 
            lenders and borrowers over repayment plan terms.  

          8)Require licensees to prominently disclose that borrowers have 
            the right to request a written extension agreement and payment 
            plan.  









                                                                  AB 1158
                                                                  Page  9

          9)Require that specific language be used in payday loan 
            advertising to disclose one's licensure by DOC, and require 
            that all advertising disclosures be in the same language as 
            the advertising itself.  

          10)Require (rather than authorize) the use of a specific chart 
            to compare payday loan fees and related cost information.  
            Existing law requires licensees to post a schedule of all 
            charges and fees, as specified, and provides an example of one 
            way in which the information may be presented.  

          11)Require license applicants to list each person in charge of a 
            payday lending location, and require that person to submit 
            fingerprint information and a historical profile through a 
            Statement of Identify and Questionnaire (SIQ).  Require the 
            licensee to notify DOC within ten days of a change in the 
            person responsible for the location, and to submit new 
            fingerprint information and an SIQ for that person.  Require 
            each licensee to notify DOC at least 60 days prior to a change 
            of its officers, directors, or any other persons named in the 
            application.  

          12)Confirm DOC's jurisdictional nexus over payday lending 
            activities by stating that a payday lender is subject to the 
            CDDTL when it conducts deferred deposit transaction business 
            "in this state."  

          13)Expand the grounds for barring, suspending, or censuring 
            persons managing or controlling payday lenders, and for 
            denying, suspending, or revoking licenses

          14)Allow DOC to issue administrative orders to prevent unsafe 
            and injurious practices, and make these orders effective 
            within 30 days, if no hearing is requested by the person(s) 
            accused.  Allow DOC to suspend or revoke a license for failing 
            to maintain a surety bond, as required by law, through more 
            expedient administrative orders.  

          15)Increase the civil penalty for violating the payday loan law 
            from $2,500 to $10,000 per violation.  Allow administrative 
            penalties of up to $2,500 per violation to be levied and 
            collected through specified administrative hearing procedures. 


          16)Require the preparation and retention of accurate records and 








                                                                  AB 1158
                                                                  Page  10

            reports by licensees.  

          17)Authorize the Commissioner to subpoena all books and records 
            of payday lenders.  

          18)Allow DOC to seek a court order to enforce any administrative 
            decision awarding restitution, administrative penalties other 
            than citations, and cost recovery, without having to file a 
            civil suit and motion for summary judgment.  

          19)Provide that a citation is deemed final if the cited licensee 
            fails to request a hearing within 30 days of receiving the 
            citation.  Allow DOC to issue a citation to assess an 
            administrative penalty, not to exceed $2,500 per violation 
            (rather than $2,500 per citation).  

          20)Streamline DOC's ability to void loans and order fees 
            forfeited.  Clarify that DOC has the authority to order the 
            voiding of loans and the forfeiture of fees by administrative 
            order, rather than by pursuing a civil suit.  

          21)Change the payday loan origination fee from a percentage of 
            the face value of the check to a flat fee.  

          22)Increase the maximum amount of a payday loan from $300 to 
            another amount, such as $500 or $750.  

          23)Adjust fees based on the loan amount, with a sliding scale 
            that reduces the fee as the amount borrowed goes up.  

          24)Prohibit a licensee from entering into a deferred deposit 
            transaction with a customer during the period-of-time that the 
            customer has an outstanding deferred deposit transaction with 
            another licensee.  

          25)Restrict a customer from having a payday loan outstanding 
            with any payday lender for more than three months during a 
            twelve-month period.  

          26)Require licensees to offer a payment plan with a minimum of 
            six equal, monthly installment payments to all borrowers who 
            have had continuous (consecutive) loans for three months, and 
            prohibit licensees from charging customers any additional fees 
            or interest in connection with the payment plan.  









                                                                  AB 1158
                                                                  Page  11

          27)Require all licensees to use a uniform database to record all 
            transactions in real time.  

           Some updated statistics  .

          The 2009 Annual Report, Operation of Deferred Deposit 
                  Originators Under the California Deferred Deposit Transaction 
          Law, offers some updated statistics on the payday lending market 
          for 2009.

          1)Total dollar amount of transactions: $3,099,358,316

          2)Total number of transactions: 11,784,798

          3)Average annual percentage rate: 414%

          4)Total number of returned checks for DDT transactions: 677,616

          5)Total dollar amount of returned checks: $178,369,234

          6)Total number of returned checks recovered (including partial 
            recoveries): 432,284

          7)Total dollar amount of returned checks recovered: $98,998,954

          8)Total number of checks charged-off: 280,233

          9)Total dollar amount charged-off: $72,023,747

          10)Number of licenses revoked: 25

           Arguments in support:
           
          The Community Financial Services Association and the California 
          Financial Service Providers' Association write in support:

               Quite simply, the current payday advance limit is outdated. 
                It was put into effect nearly 16 years ago when short-term 
               loans were established in California.  Officials from the 
               California Department of Corporations (which has 
               jurisdiction over deferred deposit lenders) stated in their 
               annual report that the current maximum payday advance of 
               $300 is too low to meet the common emergency needs of many 
               customers and should be raised between $500 and $750.  As 
               you know, California is one of the most costly states in 








                                                                  AB 1158
                                                                  Page  12

               which to live, and yet the state has one of the lowest 
               advance limits in the nation.  The $300 limit does not 
               always meet the needs of families who have run out of 
               financial resources, especially in these tough economic 
               times.

           Arguments in opposition:

           A coalition of community and consumer organizations write in 
          opposition:

               In November, after a landslide vote, Montana joined 15 
               other states and the District of Columbia in placing 
               double-digit limits on the interest that payday lenders can 
               charge.  With shrinking profits in other states, payday 
               lenders are turning to California in an attempt to preserve 
               their profit margins on the backs of struggling 
               Californians, by seeking to increase the allowable loan 
               amount to $500.  Earlier this month, the San Diego City 
               Council unanimously voted to adopt a Council resolution 
               against the usurious interest rates and predatory business 
               model of the payday lenders calling on the California State 
               Legislature to enact a 36% APR interest rate cap on payday 
               loans.

               Current California law allows a borrower to write a check 
               for a maximum of $300 to borrow $255.  The high cost of 
               payday loans (459% APR), together with the short two-week 
               repayment term, virtually ensures that cash-strapped 
               borrowers will not be able to meet their basic expenses and 
               pay off their loan at their next payday.  It follows, then, 
               that increasing the amount of debt payday borrowers owe 
               will only increase the likelihood that payday borrowers 
               will not be able to pay off the loan at their next payday, 
               and will be more likely to land in the debt trap.  

           Payday loan alternatives  .

          What payday loan alternatives exist for consumers?  Over the 
          last 30 years consumer lending has undergone a significant shift 
          in that most depository financial institutions moved away from 
          offering small dollar personal loans.  It appears that in some 
          cases the small consumer loan business is beginning to find its 
          way back into the branches of banks and credit unions.  However, 
          it would be fair to say that a major gap still exists in the 








                                                                  AB 1158
                                                                  Page  13

          small dollar consumer loans market place.  That niche is 
          currently dominated by payday lenders.  Some of these products, 
          such as payday advances tied to checking or savings accounts 
          offered by banks and credit unions would appear to be a step in 
          the right direction that offer consumers a viable alternative.  

          Several credit unions in California have started offering payday 
          loan type products.  For example, Patelco Credit Union in San 
          Francisco offers a revolving credit line of up to $750 with a 
          $10 fee per withdrawal which equals a 17.8% APR.  This type of 
          loan requires at a minimum a credit check.   Golden 1 Credit 
          Union, California's largest credit union, also has a payday loan 
          type product.  Nationwide, several federal credit unions offer 
          these products varying in loan amounts from $50 to $500 with a 
          range of interest rates and charges.  However, it is important 
          to note that due to differences in state and federal law, state 
          chartered credit unions in California may not offer services to 
          non-members.  The instant nature of the transaction with a 
          payday lender is not similar to that of a credit union where the 
          borrower must be a member and go through a loan underwriting 
          process.

          Additionally, several banks offer short-term type loan products 
          for their customers under a cash advance program.  According to 
          the DOC report referenced earlier,

               An example of a cash advance program is the Direct Deposit 
               Advance Service offered by Wells Fargo Bank that allows a 
               customer to obtain an advance up to $500 or a lesser limit 
               established for the customer, in $20 increments. The charge 
               is $2 dollars for every $20 advanced. The funds advanced 
               are deposited into the customer's checking account. In 
               order to qualify for the Direct Deposit Advance program, 
               the customer is required to have a recurring electronic 
               direct deposit of $100 or more from an employer or outside 
               source. The advance must be repaid within 35 calendar days. 
               The advance plus the fee is automatically withdrawn from 
               the borrower's account on the date funds are electronically 
               deposited into the borrower's account. For customers that 
               obtain advances for 12 consecutive statement periods, the 
               credit limit will be reduced by $100 in each future 
               statement period, until the credit limit reaches zero or an 
               advance is not obtained for one statement period. 

               US Bank also offers a Checking Account Advance product that 








                                                                  AB 1158
                                                                  Page  14

               allows a customer in California to obtain an advance up to 
               $300 or half the direct deposits made into the account 
               within the most recent statement cycle, in $20 increments. 
               To be eligible, the checking account must have received a 
               direct deposit of $100 or more from an employer or outside 
               agency for at least two consecutive statement cycles, one 
               of which must have been received within the last 35 
               calendar days. The finance charge is one dollar for every 
               ten dollars advanced and must be repaid within 35 calendar 
               days. Payments are automatically deducted from the checking 
               account at the time a direct deposit of $100 or more is 
               made into the account. A customer that obtains nine 
               consecutive advances will be ineligible for an advance for 
               the next three months.

          In February 2008, the Federal Deposit Insurance Corporation 
          (FDIC) issued guidance for financial institutions to establish 
          pilot programs for small dollar loan programs.  The FDIC 
          guidelines provided for the following parameters of the program:

          1)Loan amounts of up to $1,000; 

          2)Amortization periods longer than a single pay cycle and up to 
            36 months for closed-end credit, or minimum payments that 
            reduce principal (i.e., do not result in negative 
            amortization) for open-end credit; 

          3) APRs below 36 percent; 

          4)No prepayment penalties; 

          5)Origination and/or maintenance fees limited to the amount 
            necessary to cover actual costs; and, 

          6)An automatic savings component. 

          This pilot program began with 31 banks.  According to the FDIC, 
          the participating banks thus far view the program as a long-term 
          strategy to attract new customers and new relationships.  
          Additionally, only one California bank participated in the 
          pilot.

          On the flip-side, other alternatives exist that may be far worse 
          than payday loans.  Unregulated internet lending exists that 
          using interest rates and charges far exceeding those regulated 








                                                                  AB 1158
                                                                  Page  15

          under California law.

           Issues for Discussion  .

          This bill raises the face value of the check accepted as 
          collateral for the payday loan to $500, meaning that based on 
          the fee parameters in current law a consumer would write the 
          lender a check for $500 and receive a loan of $425.  The APR on 
          this two-week transaction would be 460%.

          The battle over the appropriateness of the payday loan product 
          has been the subject of numerous bills appearing before this 
          committee in recent years.   This issue arises due to a lack of 
          small dollar products in the market place.  Thus far, the 
          availability of loan products between the payday limit of $255 
          and $2500 is virtually non-existent outside of a few pilot 
          projects.  The most recent attempt to expand the small dollar 
          loan market occurred via SB 1146 (Florez), which became law 
          January 1, 2011.  This bill established a pilot project under 
          the California Finance Lender's Law to offer consumer loans of 
          less than $2500.  At this point, it is unclear how much of 
          impact this product will make in this market.  It may take 
          several years to truly understand its impact.

          Consumer organizations highlight that payday loans are a "debt 
          trap" meaning that the borrower gets stuck in a cycle of debt 
          leading to further deficits in personal income.  For example, if 
          the borrower doesn't have $255 today for expenses then will the 
          borrower have the extra money after paying their regular bills, 
          to pay back the loan in two weeks when the loan comes due?  In 
          many cases, the borrower simply takes out additional loans, 
          back-to-back, in an attempt to make up the lack of personal 
          funds.

          The DOC report referenced at length in this analysis made 
          several recommendations regarding potential changes to the DDTL. 
           In the discussion regarding increasing the loan limit, the DOC 
          report also offers for consideration a sliding scale of charges 
          based on the amount borrowed.   This bill only makes one of 
          those changes.  Should this bill be amended to specify further 
          changes?

           Amendments?
          
          Should this bill move forward the committee and author may want 








                                                                  AB 1158
                                                                  Page  16

          to consider additional amendments such as:

          1)A sliding scale of fees based on the amount borrowed.

          2)Increase civil penalties for violating loan DDTL from $2,500 
            to $10,000 per violation.  Allow administrative penalties of 
            $2,500.

          3)Enhance DOC's ability to void loans and recoup fees for 
            borrowers via administrative orders rather than through civil 
            suit.

          4)Require repayment plans to be in writing specifying payment 
            dates and amounts of each payment and require licensees to 
            advertise the availability repayment plans.  

          5)Allow DOC to request and audit all licensee records.

          6)Increase licensing fee for enforcement costs.

          7)Allow DOC to suspend activity at a licensed location if 
            commissioner finds that the location is making DDTs without 
            regard customer's ability to repay the loan.

           Prior State Legislation 

           AB 2511 (Skinner).  Would have prohibited the offering of a 
          payday loan to someone receiving unemployment benefits, unless 
          the APR for the loan was 36%.  Held in Assembly Banking 
          Committee. 

          AB 377 (Mendoza). Provided for various changes and reforms to 
          the DDTL.  Additionally, would have raised the face value of the 
          check amount to $500.  Died in Senate Judiciary. 

          AB 2845 (Jones, Bass & Feuer).   At one point, would have capped 
          the APR on payday loans at 36%.  Was amended in Assembly Banking 
          & Finance committee to state the intent of the Legislature to 
          enact changes recommended in the DOC reports.  Held in Assembly 
          Rules Committee.

          SB 1959 (Calderon, Chapter 682, Statutes of 1996):  Enacted the 
          earliest version of a payday lending law in California.  Gave 
          regulatory authority to the California Department of Justice. 









                                                                  AB 1158
                                                                  Page  17

          SB 898 (Perata, Chapter 777, Statutes of 2002).  Enacted the 
          Deferred Deposit Transaction Law and shifted the responsibility 
          for administering the law to DOC;

          AB 7 (Lieu, Chapter 358, Statutes of 2007): Gave DOC the 
          authority to enforce specified federal protections granted to 
          members of the military and their dependents under the Payday 
          Lending Law.  
           
           SB 1551 (Correa): Would enact various changes intended to 
          improve regulatory oversight of the payday lending based on 
          recommendations found in the two reports referred to in this 
          analysis.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Hispanic Chambers of Commerce
          Academia Avance
          League of United Latin American Citizens (LULAC)
          Initiation Change in Our Neighborhoods (ICON)
          The Community Financial Services Association (CFSA)

           

          Opposition 
           
          AARP, California
          African American Network of Kern County
          Alliance of Californians for Community Empowerment (ACCE)
          Asian Law Alliance
          Black Economic Council
          California Association for Micro Enterprise Opportunity
          California Labor Federation AFL/CIO
          California Reinvestment Coalition
          California Teamsters Public Affairs Council
          Catholic Charities of California United
          Center for Responsible Lending
          Coalition for Quality Credit Counseling
          Consumers Union
          Council of Mexican Federations
          Dolores Huerta Foundation
          East Los Angeles Community Corp. (ELACC)
          Greater Sacramento Urban League








                                                                  AB 1158
                                                                 Page  18

          Greenlining Institute Insight 
          Honorable Jose Cisneros, Treasurer, City & County of San 
          Francisco
          JERICHO
          National American Indian Veterans Inc.
          National Asian American Coalition
          National Council of La Raza, CA
          New America Foundation
          Opportunity Fund Northern California
          Public Interest Law Firm
          Sacramento Housing Alliance
          Silicon Valley Community Foundation
          Teamsters Public Affairs Council
          The Americas Group
          Ubuntu Green
          United Way of California
          Western Center on Law & Poverty
           
          Analysis Prepared by  :    Mark Farouk / B. & F. / (916) 319-3081