BILL ANALYSIS Ó
SENATE COMMITTEE ON
BANKING AND FINANCIAL INSTITUTIONS
Senator Marty Block, Chair
2015 - 2016 Regular
Bill No: SB 235 Hearing Date: April 15,
2015
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|Author: |Block |
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|Version: |February 17, 2015 |
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|Urgency: |No |Fiscal: |Yes |
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|Consultant:|Eileen Newhall |
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Subject: Small dollar loans: finder duties and compensation
SUMMARY Authorizes finders under the Pilot Program for Increased
Access to Responsible Small Dollar Loans to disburse loan
proceeds to borrowers, receive loan payments from borrowers, and
provide notices and disclosures to borrowers, as specified, and
authorizes pilot program lenders to enter into compensation
agreements with their finders in accordance with compensation
schedules that are mutually agreed to by the lender and the
finder, rather than statutorily prescribed under California law.
DESCRIPTION
1. Authorizes finders under the Pilot Program for Increased
Access to Responsible Small Dollar Loans (pilot program) to
provide the following services on behalf of the pilot
program lenders with which they have a written agreement.
These services are in addition to the eight services finders
are authorized to provide on behalf of pilot program lenders
under existing law:
a. Disbursing loan proceeds to a borrower, if this
method of disbursement is acceptable to the borrower.
Any loan disbursement made by a finder is deemed made by
the licensee on the date that funds are disbursed or
otherwise made available by the finder to the borrower.
b. Receiving loan payment or payments from the
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borrower, if this method of payment is acceptable to the
borrower.
i. Any loan payment made by a borrower to a
finder is deemed received by the licensee as of the
date the payment is received by the finder and must
be applied by lender to the borrower's outstanding
loan.
ii. A finder who receives loan payments must
provide a receipt to the borrower making the payment
at the time the payment is made. This receipt must
include the date of payment, total payment amount
made, and the corresponding loan account upon which
the payment is being applied.
iii. A borrower who submits a loan payment to a
finder may not be held liable by the lender for any
failure or delay by the finder in transmitting
payment to the lender.
c. Providing any notice or disclosure required to be
provided to the borrower by the lender.
2. Deletes the existing law cap on fees that licensees may pay
finders, replaces the reference to finder's "fees" in
existing law with a reference to finder's "compensation,"
and provides that compensation may be paid by a licensee to
a finder in accordance with a compensation schedule that is
mutually agreed to by a licensee and a finder.
EXISTING LAW
3. Until January 1, 2018, authorizes the pilot program within
the California Finance Lenders Law (CFLL), administered by
the Department of Business Oversight (DBO; Financial Code
Sections 22365 et seq.).
4. Authorizes CFLL licensees that are approved by the
Commissioner of Business Oversight (commissioner) to
participate in the pilot program to use the services of one
or more finders, as specified. Defines a finder for
purposes of the pilot program as an entity that, at the
finder's physical location for business, brings a pilot
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program lender and a prospective borrower together for the
purpose of negotiating a loan contract. Clarifies that an
entity, whose sole means of bringing a licensee and a
prospective borrower together at that entity's physical
location for business, is via an electronic access point
through which a prospective borrower may "click through" to
the Internet Web site of a pilot lender, is not a finder
(Section 22371).
5. Requires all agreements between a pilot program lender and
its finders to be set forth in writing and to contain a
provision establishing that the finder agrees to comply with
all regulations established by the commissioner related to
the pilot program and agree to provide the commissioner
access to all of the finder's books and records that pertain
to the finder's finding activities (Section 22375).
6. Authorizes finders to perform one or more of the following
services for a pilot program lender at the finder's physical
location for business (Section 22372):
a. Distributing, circulating, using, or publishing
preprinted brochures, flyers, fact sheets, or other
written materials relating to loans that the pilot
program lender may make or negotiate, which have been
reviewed and approved in writing by the lender prior to
their being distributed, circulated, or published.
b. Providing written factual information about loan
terms. conditions, or qualification requirements to a
prospective borrower that have either been prepared by
the lender or reviewed and approved in writing by the
lender. A finder may discuss that information with a
prospective borrower in general terms, but may not
provide counseling or advice to a prospective borrower.
c. Notifying a prospective borrower of the information
needed to complete a loan application, without providing
counseling or advice to the borrower.
d. Entering information provided by a prospective
borrower on an application form or into a database,
without providing counseling or advice to the borrower.
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e. Assembling credit applications and other materials
obtained in the course of a credit application
transaction for submission to the lender.
f. Contacting the lender to determine the status of a
loan application.
g. Communicating a response that is returned by the
licensee's automated underwriting system to a borrower.
h. Obtaining a borrower's signature on documents
prepared by the licensee and delivering final copies of
the documents to the borrower.
7. Prohibits finders from engaging in any of the following
activities (Section 22372):
a. Providing counseling or advice to a borrower or
prospective borrower.
b. Providing loan-related marketing material that has
not previously been approved by the pilot lender to a
borrower or prospective borrower.
c. Interpreting or explaining the relevance,
significance, or effect of any of the marketing materials
or loan documents the finder provides to a borrower or
prospective borrower.
d. Negotiating the price, length, or any other loan
terms between a pilot lender and a prospective borrower
(unless separately licensed as a finance broker under the
CFLL).
e. Advising a prospective borrower or a pilot lender as
to any loan term (unless separately licensed as a finance
broker under the CFLL).
8. Authorizes pilot program lenders to compensate finders
pursuant to a written agreement, subject to all of the
following limitations (Section 22374):
a. No fee may be paid by a lender to a finder in
connection with a loan application until and unless that
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loan is consummated.
b. No fee may be paid by a lender to a finder based on
the principal amount of the loan.
c. No fee paid to a finder may exceed $45 per loan for
the first 40 loans originated each month at the finder's
location and $40 per loan for any subsequent loans
originated during that month at the finder's location.
d. No lender may, directly or indirectly, pass on to a
borrower any fee, or any portion of any fee, that the
lender pays to a finder in connection with that
borrower's loan or loan application.
9. Requires finders to provide a disclosure to each
prospective borrower with which it interacts on behalf of a
pilot program lender on behalf of that lender, which says
the following in no smaller than 10-point type: "Your loan
application has been referred to us by [Name of Finder]. We
may pay a fee to [Name of Finder] for the successful
referral of your loan application. IF YOU ARE APPROVED FOR
THE LOAN, [NAME OF LICENSEE WILL BECOME YOUR LENDER, AND YOU
WILL BE BUILDING A RELATIONSHIP WITH [NAME OF LICENSEE] If
you wish to report a complaint about [Name of Finder] or
[Name of Licensee] regarding this loan transaction, you may
contact the Department of Business Oversight, Division of
Corporations at 1-866-ASK-CORP (1-866-275-2677), or file
your complaint online at www.corp.ca.gov ." (Section 22373)
10. Requires each licensee that utilizes the services of one or
more finders to inform the commissioner regarding the
identities of and contact information for their finders, as
specified; pay an annual finder registration fee to the
commissioner to cover the commissioner's costs to regulate
their finders; and submit an annual report to the
commissioner, containing whatever information the
commissioner requests related to the finder's finding
activities (Section 22375).
11. Authorizes the commissioner to examine the operations of
each finder to ensure that the activities of the finder are
in compliance with the pilot program and its implementing
regulations, and requires the costs of the commissioner's
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examination of each finder to be charged to the licensee
with which the finder has its agreement. Provides that any
violation of the pilot program or its regulations by a
finder or a finder's employee is attributed to the lender
(Section 22377).
12. Gives the commissioner authority to disqualify a finder
from performing services under the pilot program, bar a
finder from performing services at one or more specific
locations, terminate a written agreement between a finder
and a pilot program lender, and prohibit the use of a finder
by all licensees accepted to participate in the pilot
program, if the commissioner determines that the finder has
violated the pilot program rules or regulations.
Additionally authorizes the commissioner to impose an
administrative penalty of up to $2,500 for violations of the
pilot program that are committed by a finder (Section
22377).
COMMENTS
1. Purpose: SB 235 is sponsored by Insikt Corporation to
improve the viability of California's small-dollar loan
pilot program. By removing bureaucratic hurdles that have
discouraged the use of finders by pilot program
participants, the sponsor believes that the bill will help
increase the availability of pilot program loans throughout
California.
2. Background: Relatively few installment loans are made in
California with principal amounts under $2,500. This
represents a challenge to the significant population of
people in California who are unable to access affordable
credit through banks and credit unions. Californians who
lack credit scores, or have very thin credit files or
damaged credit, currently have very few affordable options
when they need to borrow money. Credit cards are often
unavailable to this population, or, if available, bear very
high interest rates and fees. When their spending needs
outpace their incomes, these Californians commonly turn to
payday loans, auto title loans, or high-interest rate,
unsecured installment loans. All three of these options
come with high costs, and none rewards timely loan repayment
with a credit score increase.
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Recognizing California's shortage of affordable, credit-building
loans, the California Legislature authorized a small-dollar
loan pilot program in 2010 (SB 1146, Florez, Chapter 640,
Statutes of 2010). The Legislature modified that pilot
program in 2013, based on pilot participants' first two
years of experience, with the aim of attracting more lenders
to the program and increasing the viability of lenders
participating in the pilot (SB 318, Hill, Chapter 467,
Statutes of 2013). SB 235 proposes to modify one element of
the 2010 pilot that has not yet been updated to reflect
knowledge gained through pilot participants' experience:
the finder provisions.
As envisioned in the 2010 legislation, finders are third parties
who can work on behalf of pilot program lenders to identify
prospective borrowers and connect them with the lenders,
helping to lower pilot program lenders' costs of customer
acquisition. Until very recently, however, no pilot program
licensee had utilized the finder authority granted in the
2010 legislation, because the finder provisions have proven
too rigid for the realities of the small dollar loan
marketplace. SB 235 is premised on the belief that the
finder provisions require revision, if the pilot program is
to achieve its full potential.
3. Discussion: Recently, the Insikt Corporation, parent company
of Lendify, a new entrant to the pilot program, devised a
way to utilize finders as an integral part of its business
model. However, Insikt has run into two bureaucratic
hurdles in its attempts to implement Lendify's finder
roll-out. First, although existing law authorizes finders
to engage in several specific activities (generally
involving the distribution of information about pilot
program loans and acting as a communications link between
prospective borrowers and pilot program lenders), existing
law is silent on whether finders may disburse loan proceeds
or required disclosures to approved borrowers or accept
periodic loan payments from borrowers. Insikt's business
model seeks to give borrowers the freedom to decide how and
from whom they wish to receive their loan proceeds and how
and to whom they wish to make their periodic payments -
flexibility that current law fails to authorize, but which
this bill would.
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Second, the original 2010 legislation authorized only one, very
simplified method of finder compensation: a per-loan fee
paid by a pilot program licensee to a finder at the time of
loan consummation (the 2010 legislation capped fees at the
somewhat arbitrary levels of $45 per loan for the first 40
loans originated each month at a finder's location and $40
per loan for any subsequent loans originated during that
month at a finder's locations). These simple compensation
schemes fail to reflect the realities of today's financial
services marketplace. Both Insikt and its finders would
prefer to utilize a compensation schedule that treats
finders as partners in Insikt's loan portfolio. Insikt is
seeking the flexibility to pay its finders as its program
loans are repaid, rather than up front, and to compensate
finders based on negotiated amounts that reflect the size of
Insikt's performing loan portfolio, rather than a set amount
per loan. These proposed changes would not revise the
requirements in existing law that finders be compensated
only for consummated loans, nor the prohibition against
compensating finders based on the principal amount of a
loan; both of those consumer protections would remain.
4. How Many Pilot Lenders Are There, and How Many Loans Are
They Making? According to DBO, a total of seven lenders
have been approved to participate in the pilot program to
date, including Progreso Financiero, LendUp, Fairloan
Financial, Lendify Financial (owned by Insikt), Avanza
(operating as Listo!), International Rescue Committee, and
Cyco Financial Services Center. Because annual reports for
the 2014 calendar year are not yet publicly available, and
because only three pilot lenders made loans in 2013,
information is limited regarding the number of loans made
under the pilot.
On the basis of 2013 annual reports for Progreso Financiero,
LendUp, and Fairloan Financial, slightly over 125,000 pilot
program loans totaling approximately $140 million were made
by pilot program lenders during 2013.
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| | Number of | Principal |
| | Pilot Program | Amount of |
| | Loans Made | Pilot Program |
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| | |Loans Made |
|---------------+---------------+---------------|
|Progreso | | |
|Financiero | 125,262 | |
| | |$139,534,300 |
|---------------+---------------+---------------|
|LendUp | 2,674 | |
| | |$432,690 |
|---------------+---------------+---------------|
|Fairloan | | $ |
|Financial |68 |66,390 |
| | | |
-----------------------------------------------
5. Summary of Arguments in Support:
a. Insikt, Inc., sponsor of SB 235, is "a white-label
loan origination and investing platform that enables any
brand to lend to its customers and any accredited
investor to invest in consumer loans....Insikt seeks to
ensure that all people have access to affordable loans
based on more than their credit score and whether they
have a banking relationship. Insikt does this by
providing a technology solution for retailers, brands,
and online companies - all of whom are finders - to make
loans to their customers without having to take risk,
invest in systems, or figure out how to fund their
loans." Insikt was founded in 2012 by James Gutierrez,
the founder and original chief executive officer of
Progreso Financiero.
Insikt is sponsoring SB 235 for two key reasons. "First,
existing law is silent on whether a finder may disburse
loan proceeds and accept loan payments from borrowers.
This was because, originally, the concept was that
finders would be merchants who would deliver goods to the
consumers instead of disbursing loan funds. However,
Insikt has taken the model beyond a mere substitute for
retail installment sales, and now provides loan funds for
purposes beyond the purchase of durable goods from a
retailer/finder. Insikt believes that borrowers should
have the freedom to decide how and from whom they receive
their loan proceeds and how and to whom they wish to make
their payments - flexibility that current law fails to
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authorize, but which this bill would enable. A
customer's ability to obtain loan proceeds and make loan
payments expeditiously and in a convenient manner is
simply a fundamental customer need."
Second, the original 2010 legislation authorized only one
rigid compensation scheme for finders - a per loan fee
paid by a pilot program licensee to a finder at the time
of loan origination. Insikt and its finder partners are
seeking the flexibility to negotiate compensation
agreements that work for both parties. Failure to
provide that flexibility as part of the pilot program
risks discouraging potential partnerships between pilot
program lenders and finders, to the ultimate detriment of
consumers, who will find themselves with less, rather
than more, access to pilot program loans.
Insikt argues that increased flexibility around finder
compensation agreements will not have the negative
consequences feared by this bill's opponents. First, the
amount of finder compensation has no impact on a
borrower's cost, because pilot program lenders are
prohibited from passing the cost of finder compensation
on to their borrowers. If the cost of the loan to the
borrower remains unchanged, why should it matter how the
lender and finder split revenue derived from a loan?
Second, Insikt believes that concerns about excessive
finder compensation are unfounded; the low principal
amounts, low rates, and low fees that may be charged
under the pilot program result in very small (if any)
profit margins. There is simply too little margin
available under the existing pilot program to accommodate
the payment of excessive compensation.
b. Several of Insikt's current and potential future
finder partners also support SB 235. For example,
Avanza, Inc. (which operates under the name Listo!) is a
new company that provides a range of financial services,
including pilot program loans, to lower-income Latino
families. As a start-up, Listo! initially lacked the
resources to develop a software and underwriting system
capable of making loans directly to consumers. However,
in partnering with Insikt as a finder, Listo! has access
to the capability and systems of an approved pilot
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program lender, which allows it to offer affordable,
credit-building loans to its customers. Listo! is
committed to providing underbanked families in California
access to capital and opportunities. Listo! supports SB
235, because it will improve one of the key goals of
California's pilot program: access.
Listo! writes, "After five years, only one pilot program
lender has applied to register a finder. As we've
learned through our experience, the finder provisions, as
currently written, are inadequate....SB 235 takes a step
in the right direction of increasing the availability of
pilot program loans by making the finder provisions
workable....In order for us to continue providing pilot
program loans to our customers without risk to our
operation, we need to fix the finder provisions in the
pilot program."
Check Agencies of California, Inc (which operates under the
name Check Center) is another of Insikt's finder partners
that supports SB 235. Check Center describes itself as a
socially responsible, CFLL licensee that has provided
financial services and loan products to underserved and
underbanked borrowers across California for 30 years.
Check Center's products include payday loans, small
business finance, bill pay, money transfer, and check
cashing. In August 2014, Check Center partnered with
Insikt's lending subsidiary (Lendify Financial) to offer
pilot program loans. "Our goal was to provide our
customers access to larger, lower-cost, pilot program
loans. Since launching, Lendify's loan product has been
extremely well received by our team members and customers
with almost 2,000 loan applications processed at seven
locations across California. Based on this success, we
will soon expand Lendify's offering to all of our 19
locations. We are, however, concerned that existing law
does not expressly permit finders like ourselves to
disburse loans, nor to accept payments made by borrowers
at finder locations. When we first applied to be a
finder (in partnership with Lendify), we were initially
declined by the Department of Business Oversight because
of our intention to disburse loans and take payments
(which is a natural expectation of any customer who
applies for a loan with us). As a CFL regulated by the
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DBO, we were ultimately approved as a finder with the
ability to disburse funds and receive payments, but not
without risk. We are concerned that without a
legislative fix to the finder provision in the pilot
program, our plans to provide customer access to lower
cost pilot program loans could be jeopardized."
Check Center also observes, "It's hard to contemplate
making a loan to a borrower without giving them a
convenient way of repaying that loan. In our experience,
underbanked consumers operate largely in cash and are
accustomed to paying for many of their bills in cash.
Any provision that prohibits borrowers from making
in-person loan payment unfairly disadvantages underbanked
families and, thus, in our opinion, defeats the purpose
of the pilot program."
c. uTax Software is one of the largest tax industry
service providers in the country. It would like to enter
into a finder partnership with Insikt, and, in doing so,
allow its network of tax preparation professionals offer
Insikt's responsibly priced lending product to thousands
of low- and moderate-income customers in California. "We
are concerned, however, that existing law may be a
barrier to a partnership with Insikt because it is silent
as to whether a finder, approved by the Department of
Business Oversight under the pilot program, may disburse
loans to approved borrowers and accept loan payments from
those borrowers. Our tax professionals offer year round
financial services to customers, and many of them are
agents of money transmitters - sending and receiving cash
on behalf of customers every day. These customers
transact almost all of their business in cash and need
the ability to receive loans and make payments in cash at
the retail location where the loan was made. The
amendments proposed by SB 235 are therefore essential."
d. LendUp, an existing pilot program participant, is
also supportive of SB 235. "SB 1146 was truly
revolutionary in structure; it codified in law that
lenders should be rewarded for responsible underwriting,
credit building access, and credit education...and while
we have a handful of companies that have gotten funding
and started lending responsibly - companies that have
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significant social impact goals and who wish to do public
good - we need more...The finder's provisions in the
original bill were intended to give consumers more
locations where they could apply for pilot program loans
and to encourage partnerships that could lower the cost
of customer acquisition for lenders." However, the
current finder provisions fail to achieve SB 1146's
original objectives. Therefore, "we think SB 235 will
take the best of what we have learned with the original
pilot program and encourage more participants and finders
to enter the space."
LendUp also sees SB 235 as important, because it will allow
Silicon Valley and like-minded technology players to
facilitate more competition within the market for
responsible small dollar loans. There are a number of
people, businesses and community groups that want to help
provide better, safer lending alternatives in California,
but are unable to do so due to the complex and expensive
regulatory environment we live in. SB 235 will allow
able, willing, and motivated parties to use technology to
solve problems.
6. Summary of Arguments in Opposition:
a. The Center for Responsible Lending (CRL) and
Consumers Union (CU) support the general goal of
expanding access to credit, but believe that such
expansions must be both affordable and responsible. Both
groups are opposed to SB 235. "When we negotiated the
original pilot program...we focused much attention on the
issue of finders. As originally conceived, the finders
would play a very limited role and would essentially
connect potential borrowers with lenders under the pilot
program, and provide pre-printed materials to the
borrower. We were concerned that finders could have
perverse incentives to market loans that are not in a
consumer's interest, or to generate loans from
transactions in which the consumer was not actively
seeking credit. As such, we negotiated limits to the
role of the finder, as well as the compensation allowed
for finders. Giving finders the authority to disburse
loan proceeds, provide official notices to consumers, and
accept loan payments transforms these finders into a very
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different kind of role than the one initially
envisioned."
Under existing law, and as contemplated by SB 235, finders
are not allowed to provide counseling or advice to
borrowers, nor to interpret or explain the relevance,
significance, or effect of any of the marketing materials
or loan documents. "Given the new expanded role this
bill would give to a finder, it seems difficult to
imagine that a finder would not be put in the position of
providing some counseling or explanation to a potential
borrowers. So, either you have a finder who is illegally
serving as an unlicensed broker, or you have a loan
transaction occurring in a context in which the borrower
is interacting with a person who is prohibited from
properly assisting him or her in the decision-making
process. Either way, this is problematic. Moreover, DBO
would have limited ability to monitor a finder's loan
level transactions to ensure that the law's provisions
are being followed, especially when finders are not
subject to any licensure requirements."
CRL and CU are seeking three amendments, at a minimum.
First, they would like to limit the new finder activities
authorized by the bill to persons who are already
licensed in a field pertaining to financial transactions
(e.g., depository and nondepository lenders, money
transmitters, check sellers, bill payers, proraters,
escrow agents, pawnbrokers, insurance brokers, and real
estate licensees). Second, the organizations would like
to require that finders who disburse loan proceeds or
receive loan payments be required to maintain records of
all disbursements made and payments received for a period
of at least three years. Finally, they are concerned
about the wholesale removal of any limits or structure
around the compensation of finders. "Without some
reasonable limits on finders' compensation, we fear that
finders will be motivated to aggressively market loans to
borrowers in a range of settings, such as retail
environments where they are already trying to complete a
sale of a related product or service."
b. Although not officially opposed to the bill,
Progreso Financiero (now called Oportun) submitted a
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letter expressing concerns. Progreso would like to see
the bill amended to minimize its potential for unintended
negative consequences that could hurt, rather than help,
borrowers and create opportunities for activity that
could damage the reputation of the pilot program. Like
CRL and CU, Progreso would like to see better
qualification of the entities that will be conducting the
activities contemplated in the bill.
7. Prior and Related Legislation:
a. SB 1146 (Florez), Chapter 640, Statutes of 2010:
Authorized California's original small-dollar loan pilot
program within the CFLL, named the Pilot Program for
Affordable Credit-Building Opportunities. Allowed
lenders approved to participate in the pilot program to
charge higher interest rates and fees on loans of up to
$2,500 than those authorized under CFLL. Required pilot
program lenders to rigorously underwrite their loans,
offer credit education at no cost to their borrowers, and
report borrower payment history to at least one major
credit bureau. Required detailed reporting of loan
outcomes to DBO. Scheduled to sunset on January 1, 2015,
but was replaced by the Pilot Program for Increased
Access to Responsible Small Dollar Loans, as described
immediately below, on January 1, 2014.
b. SB 318 (Hill), Chapter 467, Statutes of 2013:
Replaced the Pilot Program for Affordable,
Credit-Building Opportunities with the Pilot Program for
Increased Access to Responsible Small Dollar Loans.
Retained several aspects of the original pilot, including
the underwriting requirements, offers of free credit
education, reports to at least one major credit bureau,
and detailed reporting of program loan outcomes, but
modified other aspects of the original pilot program.
These modifications increased the maximum interest rates
and fees that pilot lenders could charge, allow pilot
lenders to originate new loans and to refinance loans
more frequently than under the original pilot, and
eliminated several administrative and licensing rules
that were serving as bureaucratic barriers to the success
of the original pilot. Sunsets on January 1, 2018.
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LIST OF REGISTERED SUPPORT/OPPOSITION
Support
Insikt, Inc. (sponsor; parent company of Lendify)
Avanza (dba Listo!)
Check Agencies of California (dba Check Center)
LendUp
uTax Software
Opposition
Center for Responsible Lending
Consumers Union
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