BILL ANALYSIS                                                                                                                                                                                                    �






                              SENATE JUDICIARY COMMITTEE
                             Senator Noreen Evans, Chair
                              2011-2012 Regular Session


          AB 1158 (Calderon)
          As Amended April 13, 2011
          Hearing Date: July 5, 2011
          Fiscal: Yes
          Urgency: No
          SK:rm
                    

                                        SUBJECT
                                           
            California Deferred Deposit Transaction Law (Payday Lending)

                                      DESCRIPTION  

          Existing law permits payday lenders to defer the deposit of a 
          customer's personal check for up to 31 days.  The maximum value 
          of a check for a payday loan is limited to $300, and the maximum 
          fee cannot be more than 15% of the face amount of the check.

          This bill would increase the maximum value of a check for a 
          payday loan from $300 to $500.

                                      BACKGROUND  

          Current law, the California Deferred Deposit Transaction Law 
          (CDDTL), regulates payday loan lenders, and places a number of 
          restrictions on payday loans.  For example, the CDDTL requires 
          that payday lenders be licensed by Department of Corporations 
          (DOC) and permits lenders to charge a fee of 15 percent of the 
          face amount of the check which cannot have a face value of more 
          than $300.  The Act also specifies disclosure and notice 
          requirements, including that the annual percentage rate (APR) 
          and any charges and fees be disclosed to the consumer.

          Recent figures from DOC indicate that, as of December 31, 2010, 
          there were 2,144 licensed payday loan locations in California.  
          In 2010, 1.65 million Californians took out 12 million payday 
          loans worth approximately $3.13 billion.



                                                                (more)



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          The following information was obtained from DOC's "2010 Annual 
          Report: Operation of Deferred Deposit Originators under the 
          California Deferred Deposit Transaction Law" (2010 Annual 
          Report):
               
             ---------------------------------------------------------- 
            |                  |2006   |2007   |2008   |2009   |2010   |
            |------------------+-------+-------+-------+-------+-------|
            |Total dollar      |$2.55  |$2.97  |$3.1   |$3.19  |$3.13  |
            |amount of payday  |billion|billion|billion|billion|billion|
            |loans made        |       |       |       |       |       |
            |                  |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Total number of   |10.05  |11.15  |11.8   |11.88  |12.1   |
            |payday loans made |million|million|million|million|million|
            |                  |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Total number of   |1.43   |1.61   |1.67   |1.57   |1.65   |
            |individual        |million|million|million|million|million|
            |customers who     |       |       |       |       |       |
            |obtained payday   |       |       |       |       |       |
            |loans (repeat     |       |       |       |       |       |
            |customers counted |       |       |       |       |       |
            |once)             |       |       |       |       |       |
             ---------------------------------------------------------- 

          In addition, the 2010 Annual Report provides the following 
          information with respect to individual payday loans made: 

             ---------------------------------------------------------- 
            |                  |2006   |2007   |2008   |2009   |2010   |
            |------------------+-------+-------+-------+-------+-------|
            |Average dollar    |$254   |$266   |$262   |$262   |$258   |
            |amount of payday  |       |       |       |       |       |
            |loans made        |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Minimum dollar    |$10    |$10    |$6     |$8     |$4     |
            |amount of payday  |       |       |       |       |       |
            |loans made        |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Maximum dollar    |$300   |$300   |$300   |$300   |$300   |
            |amount of payday  |       |       |       |       |       |
            |loans made        |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Average annual    |429%   |424%   |416%   |414%   |414%   |
            |percentage rate   |       |       |       |       |       |
                                                                      



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            |(APR)             |       |       |       |       |       |
            |------------------+-------+-------+-------+-------+-------|
            |Average number of |16     |16     |17     |17     |17     |
            |days of payday    |       |       |       |       |       |
            |loan transactions |       |       |       |       |       |
             ---------------------------------------------------------- 

          In 2008, DOC released two reports, "California Deferred Deposit 
          Transaction Law, California Department of Corporations, December 
          2007" (DOC Report) and "2007 Department of Corporations Payday 
          Loan Study" (AMPG study).

          The DOC report was based upon a survey of payday lenders and 
          DOC's annual report for 2005-06.  The AMPG study was based on an 
          online survey of payday lenders, a telephone survey of 
          borrowers, and five customer focus groups.  AMPG's study was 
          conducted between August and December 2007, for the 18-month 
          period between April 15, 2006 through September 11, 2007.  Both 
          reports highlighted that, while a payday loan is intended to be 
          a short-term, one-time loan to meet emergency financial needs, a 
          large number of Californians use payday loans on a regular, 
          on-going basis and find that establishing a payday loan account 
          "opens the door to a repetitive cycle of borrowing that is 
          difficult if not impossible to end" (AMPG study).  The DOC 
          report also found that 2.4 percent of payday loan borrowers took 
          out more than one loan at the same time from multiple lenders. 

          In 2009, AB 377 (Mendoza), among other things, proposed to 
          increase the amount of a payday loan check from $300 to $500.  
          That increase was added to the bill after it passed the 
          Assembly.  This Committee held the bill after hearing testimony.

          Like AB 377, this bill would increase the maximum value of a 
          check for a payday loan from $300 to $500.

                                CHANGES TO EXISTING LAW
           
           Existing federal law  imposes a 36% APR on consumer credit, 
          including payday loans, extended to members of the military and 
          their dependents.  (10 USC Sec. 987.)  Existing state law gives 
          DOC the authority to enforce these protections under the CDDTL.  
          (Fin. Code Sec. 23038.)

           Existing law  regulates, under the CDDTL, deferred deposit 
          transactions, defined as a transaction in which a person defers 
          depositing a customer's personal check until a specific date, 
                                                                      



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          pursuant to a written agreement for a fee.  (Fin. Code Sec. 
          23000 et seq.)

           Existing law  places the following restrictions on payday 
          lenders:  
            limits the maximum value of the check to $300; 
           permits payday lenders to defer the deposit of a customer's 
            personal check for up to 31 days; and 
           limits the maximum fee to 15% of the face amount of the check. 
             (Fin. Code Secs. 23035(a), 23036(a).)

           Existing law  prohibits payday lenders from entering into a 
          payday loan with a customer who already has a payday loan 
          outstanding.  (Fin. Code Sec. 23036(c).)  
           
           This bill  would increase the maximum value of a check for a 
          payday loan from $300 to $500.

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes that "California currently allows the lowest 
          maximum limit for deferred deposit transaction in the country.  
          This bill aims to correct this discrepancy and allow California 
          customers the ability to address real needs in a difficult 
          economic time."
            
          Representatives of the payday lending industry, the California 
          Financial Service Providers' Association and the Community 
          Financial Services Association support the bill, writing:

            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.  As you know, California is 
            one of the most costly states in 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. 
           
           Supporter California Hispanic Chambers of Commerce writes that a 
          payday loan is a "convenient, short-term financial option �that] 
          provides a fix for families faced with the prospect of bouncing 
          checks, shutting off utilities or worse, skimping on basic needs 
          such as medical emergencies."
                                                                      



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          2.  Increasing the maximum value of a payday loan check from $300 
            to $500 
           
          Existing law provides that a payday loan check cannot have a 
          face value of more than $300.  This bill would increase that 
          amount to $500.  These amounts include the fee that payday 
          lenders may impose.  In the case of a payday loan check for 
          $300, that fee is $45.  In the case of a $500 payday loan check, 
          that fee is $75.  This increase was included in the DOC report 
          as a policy option (not recommendation), and was based on the 
          premise that payday loans will continue to be available to help 
          Californians meet short-term emergency cash needs, but that 
          longer-term installment products will be available for those 
          consumers unable to pay back the full amount of their payday 
          loans on their due dates.  

          The author and industry supporters argue that California's loan 
          limit of $300 should be increased to $500 because the current 
          limit is insufficient to meet the emergency cash needs of payday 
          loan customers, has not been adjusted since it was implemented 
          15 years ago, and is out of line with the limits in other 
          states.  Despite those contentions, any increase in the loan 
          limit must be evaluated not in terms of years since the last 
          increase, but, instead, on the collateral effects of that 
          increase on struggling consumers and whether any increase makes 
          it even harder for them to pay off their debt.  Previous 
          concerns about the risks posed by payday loans are reflected in 
          the Legislature's decision to place a cap on loan amounts.

           a.Whether current limit is sufficient to meet borrower's needs  

          With respect to whether or not the current limit is sufficient 
            to meet borrower's needs, DOC attempted to evaluate unmet 
            demand due to loan limits by focusing on the number of 
            customers who obtained more than one loan at the same time 
            from different licensees.  The sample survey, which analyzed 
            transactions of 72.2% of California's payday loan customers, 
            found that just 2.4% of the total customers in the sample 
            obtained more than one loan at the same time from different 
            licensees.  DOC concluded that for this 2.4% of borrowers, 
            "the loan amount was not sufficient to meet �their] emergency 
            credit needs.  This may be due to the loan limit being too low 
            or the licensees not willing to lend the amount needed by the 
            borrower." 
           
                                                                      



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          When the AMPG survey asked borrowers whether the amount they had 
            borrowed was the amount needed, over 60% of respondents 
            indicated that the amount they borrowed was what they needed 
            when reporting the minimum amount borrowed (79%) and the 
            maximum amount borrowed (63%).  Opponent Center for 
            Responsible Lending (CRL) argues these findings demonstrate 
            that most payday loan borrowers are satisfied with the amount 
            they received and that borrowers do not need more than the law 
            currently allows. 
           
           Interestingly, as noted in the Background, the average dollar 
            amount of payday loans has actually decreased over the last 
            several years, also suggesting that payday loan customers 
            actually do not need additional funds.

          From a policy standpoint, the cap on payday loans represents a 
            decision by the Legislature that the product should only be 
            used for a short term loan of no more than $300 (arguably due 
            to the risks involved in higher loan amounts).  If, in fact, 
            the intent in enacting the CDDTL was to provide consumers with 
            sufficient funds to meet  all  emergency credit needs, there 
            would be no cap on the amount of the loan.  Accordingly, the 
            policy choice represented by this bill is not whether the 
            current payday loan amount is sufficient to satisfy all 
            short-term credit needs, but whether the increase would 
            exacerbate the recognized risks associated with payday loans.  
            Opponent consumer groups, labor, and community organizations 
            argue that this bill would in fact aggravate the risk to 
            struggling consumers.  (See Comment 2(b).)

          b.   Effect of increasing loan limit to $500  

          As noted above, the AMPG study indicated that "�a]lthough most 
            borrowers report turning to payday lenders as a one-time 
            solution to an immediate financial need, most report that the 
            establishment of a payday loan account opens the door to a 
            repetitive cycle of borrowing that is difficult if not 
            impossible to end."  

          Payday lending has even been called a "business model that 
            encourages chronic borrowing."  (Michael Stegman, "Payday 
            Lending: A Business Model that Encourages Chronic Borrowing," 
            Economic Development Quarterly, Vol. 17 No. 1, February 2003.) 
             Because borrowers often cannot repay a loan and meet other 
            expenses, they must pay off their current loan with their 
            paycheck and then very soon afterwards, sometimes immediately, 
                                                                      



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            take out another loan.  The California Budget Project notes, 
            "�l]ess than 4 percent of payday loans went to Californians 
            who took out just a single loan during the entire year.  More 
            than 170,000 Californians took out 13 or more payday loans.  
            Nearly half (48 percent) of payday loan borrowers in 
            California take out payday loans at least once per month. . . 
            "

          As a result, the public policy question raised by this bill is 
            whether increasing the loan limit to $500 will harm payday 
            loan consumers by ensuring that they are caught in a 
            repetitive cycle and by making it even more difficult for them 
            to pay off their debt.  A borrower who has a hard time paying 
            off a $300 loan within two weeks is very likely to be unable 
            to repay a $500 loan within that timeframe. 

          In a joint opposition letter, 35 consumer, labor, and community 
            organizations write that "the high cost of payday loans, 
            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.  . . .  Borrowers get caught in a cycle of debt, 
            leaving them worse off.  It costs a typical borrower $570 to 
            pay back a single $255 loan; with a larger loan, the same 
            borrower would typically pay at least $950 for a $425 loan."

          The California Budget Project argues that the bill would have a 
            disproportionate impact on low-income women of color, writing:

               A 2007 survey of payday loan borrowers conducted for the 
               DOC revealed that well over half (59.8 percent) of 
               borrowers in California are women and three-quarters of 
               borrowers (74.1 percent) have annual household incomes 
               under $50,000.  The survey also showed that 
               disproportionate shares of payday loan borrowers are black 
               or Latino.

            According to CRL, a study recently released by the group found 
            that 76% of borrowers, after repaying one payday loan, must 
            take out another loan before their next paycheck.  The study, 
            entitled "Phantom Demand: Short-term Due Date Generates Need 
            for Repeat Payday Loans, Accounting for 76% of Total Volume," 
            found that half of all new loans are opened at the borrower's 
            first opportunity (immediately or after a 24-hour or more 
            waiting period where required).  The study, which was largely 
            based on data from Florida and Oklahoma-both states with a 
                                                                      



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            $500 loan limit-also found that  87% of new loans are opened 
            within two weeks, or generally before the next payday, and 
            only six percent of subsequent payday loans are taken out 
            longer than a month after the previous loan was paid off.  CRL 
            notes:

               This rapid, widespread re-borrowing indicates that most 
               payday borrowers are not able to both repay one of these 
               loans and clear a monthly billing cycle before having to 
               borrow again.  In essence, the bulk of payday loan demand 
               comes from borrowers who are taking out a payday loan to 
               repay a payday loan.  

            The City and County of San Francisco opposes the measure, 
            writing that "�i]n response to the proliferation of payday 
            lenders in San Francisco . . . San Francisco acknowledged the 
            need for short-term loans without predatory lending rates.  It 
            established Payday Plus SF, a micro-lending program with six 
            local credits.  San Francisco has demonstrated that better 
            alternatives to usurious payday lending rats are available and 
            therefore AB 1158 is unnecessary."

            Increasing the payday loan limit from $300 to $500 also has 
            the effect of significantly increasing the fee imposed on 
            borrowers.  Current law limits the face amount of a payday 
            loan check to $300 and the maximum fee to 15% of the face 
            amount.  As a result, under existing law, the maximum fee 
            imposed is $45.  Under this bill, increasing the payday loan 
            limit to $500 would result in a maximum fee of $75.  Assuming 
            a lender would charge, and a borrower would take, the maximum 
            amount, that fee is 67% higher than allowable under current 
            law.  With respect to the fee, Community Housing Works writes:

               Last November, after a landslide vote, Montana joined 15 
               other states and the District of Columbia in placing 
               double-digit limits on the annual interest that payday 
               lenders can charge.  With shrinking profits in other 
               states, payday lenders are trying to preserve their profit 
               margins on the backs of struggling Californians, by seeking 
               to increase the allowable loan amount from $300 to $500.

            Opponents also note that while California has one of the lower 
            limits on the amount of a payday loan, other states that have 
            higher loan limits also have restrictions on the number of 
            loans that may be taken out.

                                                                      



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            Given the concerns expressed above, DOES this bill's increase 
            of the loan limit to $500 ensure that payday loan consumers 
            are caught in a repetitive cycle of re-borrowing which may be 
            difficult if not impossible to end?

            c.   Amendments to address above concerns  

            The opposition suggests amendments to address its concerns, 
            writing:

              The fact that families are struggling to make ends meet does 
              not justify gouging these families with 459% interest on 
              two-week loans that leave families trapped in a cycle of 
              repeat borrowing.  AB 1158 is not about whether to preserve 
              or eliminate payday lending; it is about whether we are 
              going to expand an already risky and dangerous product, or 
              whether we are going to do something to better protect 
              California families in need.  The current version of AB 1158 
              would expand payday lending and exacerbate the dangers.  
              Instead, we recommend that AB 1158 be amended in ways that 
              would truly help struggling families.  




             Those suggested amendments do the following: 
                 adopt the FDIC's six-loans per household annual loan 
               limit in an effort to "�m]ake sure that extremely high cost 
               payday loans are addressing short-term emergencies, rather 
               than longer term debt;"
                 extend the minimum loan term to 31 days.  This amendment 
               is based on a DOC policy option that would "�g]ive families 
               more time to repay a payday loan without the need to borrow 
               again;" and 
                 adopt a requirement that lenders evaluate each 
               borrower's ability to repay, modeled on underwriting 
               provisions contained in the Pilot Program for Affordable 
               Credit-Building described in Comment 2.  This amendment is 
               intended to ensure that borrowers can repay the loan. 

            Should the Committee desire to pass this measure, the 
            Committee should consider the above amendments, or similar 
            alternatives, in order to better regulate and control 
            high-cost payday loans so that working families are protected.

            GIVEN THE CONCERNS RAISED ABOVE REGARDING THE IMPACT OF 
                                                                      



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            INCREASING THE PAYDAY LOAN LIMIT FROM $300 TO $500, SHOULD THE 
            BILL BE AMENDED TO PROVIDE BETTER CONSUMER PROTECTIONS TO HELP 
            STRUGGLING FAMILIES? 

          3.  Is there an alternative?  Recent legislative and 
            private-sector efforts aim to help provide a market for 
            reasonably priced small dollar loans
           
          Proponents of payday lending argue that many borrowers have no 
          alternative but to take out a payday loan.  According to the 
          Community Financial Services Association of America (CFSA), an 
          association of payday lending companies, other options are too 
          costly when compared with the fee for one payday loan.  For 
          example, borrowers may be charged late fees on credit cards or a 
          non-sufficient funds fee if they bounce a check.  Late payments 
          on utility bills also may be costly to the consumer, 
          particularly if they involve a reconnection fee.  

          As described below, however, new and emerging credit solutions 
          are entering the marketplace both through legislative and 
          private sector efforts.  Many of these are directly focused on 
          creating an alternative to high-cost payday loans.

             SB 1146 (Pilot Program for Affordable Credit-Building)   As 
            noted in the DOC report, small, unsecured installment loans 
                                                                             may be made by entities licensed under the California Finance 
            Lenders Law (CFLL).  DOC notes that the rates and fees on 
            these loans are limited, however, to an APR of about 30%, 
            compared to the average APR of 429% for a payday loan.  
            According to DOC, "�t]his by itself is a strong inducement to 
            make small, unsecured loans under the �payday loan law] as 
            opposed to the CFLL."  

            In an effort to address this lack of incentive to make small 
            dollar loans under the CFLL, last year, the Legislature passed 
            and the Governor signed SB 1146 (Florez, Ch. 640, Stats. 2010) 
            which created the Pilot Program for Affordable 
            Credit-Building.  That program is an effort to "increase the 
            availability of affordable credit-building opportunities to 
            underbanked individuals seeking low-dollar-value loans and to 
            help those individuals move into the financial mainstream."  
            (Fin. Code Sec. 22348.)

            The pilot program, which sunsets January 1, 2015, is intended 
            to provide a less costly alternative to payday loans by 
            creating a market for reasonably priced small loans and, at 
                                                                      



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            the same time, help loan recipients build credit.  Under the 
            program, participating lenders may charge a higher interest 
            rate and fees than under the current CFLL.  In March 2011, DOC 
            issued regulations implementing the program which contains the 
            following components:

                 the loan has a minimum principal amount upon origination 
               of $250 and is not more than $2,500, as specified; 
                 the interest rate of each loan is capped at 30% for the 
               unpaid balance of the loan up to and including $1,000 and 
               26% for the unpaid balance of the loan in excess of $1,000; 

                 origination fees are capped at 5% of the principal 
               amount of the loan or $65, whichever is less.  Licensees 
               are prohibited from charging the same borrower more than 
               one origination fee in any six-month period; 
                 the term of the loan is:  (1) 90 days for loans whose 
               principal balance upon origination is less than $500, (2) 
               120 days for loans whose principal balance upon  
               origination is at least $500, but is less than $1,500; and, 
               (3) 180 days for loans whose principal balance upon 
               origination is at least $1,500; 
                 licensees must report each borrower's payment 
               performance to at least one of the three major credit 
               bureaus; and, 
                 a licensee must underwrite each loan and may not make a 
               loan if it determines that the borrower's total monthly 
               debt service payments exceed 50% of the borrower's gross 
               monthly income.  In underwriting the loan, the licensee 
               must assess the borrower's willingness and ability to repay 
               and must validate a borrower's outstanding debt 
               obligations, as specified.

            The pilot program created by SB 1146 contains two critical 
            elements that are not a part of the payday loan product.  
            First, the program requires licensees to report borrowers to 
            at least one of the three major credit bureaus, unlike payday 
            loans which are not reported.  The intent of this requirement 
            is to help those borrowers who do not have a credit history to 
            establish one, and to help those borrowers who do have a 
            credit history to improve their credit scores.  Second, unlike 
            payday loans, the program requires licensees to underwrite the 
            loan and ensure that the loan is affordable to the borrower.  
            In order to avoid the possibility of lax underwriting, this 
            provision was intended to ensure that the loans offered under 
            the Pilot Program are both affordable and responsible.
                                                                      



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            While the Pilot Program for Affordable Credit-Building is just 
            getting underway, it represents an attractive affordable 
            alternative to costly payday loans for many Californians.  In 
            fact, for some people, it could arguably reduce some of the 
            need for a short-term high-cost payday loan.  Those same 
            individuals could instead apply for a more responsible 
            longer-term loan for $250 (or any amount up to $2,500) under 
            the program. 

            DOES THE RECENT PASSAGE OF THE PILOT PROGRAM FOR AFFORDABLE 
            CREDIT BUILDING REDUCE THE NEED FOR SHORT-TERM COSTLY PAYDAY 
            LOANS?

            SHOULD THE LEGISLATURE WAIT TO EVALUATE THE PILOT PROGRAM AND 
            GIVE IT TIME TO WORK BEFORE INCREASING THE PAYDAY LOAN LIMIT, 
            ESPECIALLY GIVEN THE SIGNIFICANT CONCERNS ASSOCIATED WITH THAT 
            INCREASE, AS DESCRIBED ABOVE? 

             Bank and credit union alternatives  With respect to other 
            alternatives to payday loans, the DOC report also states that 
            consumers "who do not have access to traditional sources of 
            credit (credit cards, home equity lines of credit, etc.) do 
            have alternatives to payday loans," noting that many banks and 
            credit unions have cash advance programs that provide 
            borrowers with cash that must be repaid generally within 35 
            days.  For example, the Center for Responsible Lending writes 
            about "SF Payday Plus, a collection of San Francisco credit 
            unions offering loans with interest rates of no more than 18% 
            APR.  Many other California credit unions also offer 
            small-dollar loans and accounts that include savings 
            components.  Because all payday borrowers must have a bank 
            account, and the vast majority of credit unions have eased 
            membership restrictions that were once the norm, many 
            Californians could become credit union members and take 
            advantage of their responsible lending products."

             Employer-based services   In 2010, Emerge Workplace Solutions 
            began offering loans to employees using a workplace-based 
            approach.  The company, whose goal "is to provide better 
            borrowing choices for working people and end predatory lending 
            practices," describes its loans (which require underwriting 
            and are usually approved within one to two business days) as 
            follows:

            Emerge loans are offered by FDIC community banks and federally 
                                                                      



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            regulated credit unions that offer fair interest rates (from 
            9.9 percent to a high of 19.9 percent APR) with 4-8 months to 
            pay them back, and can build your credit if you repay on time. 
            Also, it's easier to pay Emerge loans back because payments 
            are automatically transferred to the financial institution via 
            direct deposit.

             Lending circles; peer-to-peer lending   Also gaining popularity 
            are "lending circles" in which participants pool their 
            resources by making monthly contributions which are disbursed 
            among the group at agreed-upon intervals.  For example, 
            Mission Asset Fund (MAF) in San Francisco has partnered with a 
            local community development bank which holds the groups funds, 
            tracks payments and reports the results to credit bureaus.  As 
            a result, unlike payday loans, participants are able to build 
            credit.  The program, which is just over a year old, is 
            showing early signs of success:  

            An examination of the participants in the first two cestas 
            over a period of six months shows, according to MAF, that 
            credit scores rose on average by 47 points.  More 
            significantly, in Mr. Qui�onez's view, is that the same group 
            showed an increase of 9 percent in the average number of 
            "satisfactory" credit accounts held by members of the group. 
            "Satisfactory" accounts are those where payments are being 
            made on time. That nine-point gain demonstrates that 
            participants are not only making their contributions on time, 
            they are also improving their payment performance on other 
            credit accounts. Qui�onez believes that MAF's approach to 
            helping individuals join cestas, which includes a measure of 
            financial education, is improving how they handle all their 
            financial affairs.  ("My lender, my friend: Lending circles 
            with a Latino twist," Christian Science Monitor, January 30, 
            2010.)

             Other alternatives   Others argue that payday loan consumers 
            also have other options ranging from borrowing money from 
            friends or family, working out a payment plan with the 
            creditor (e.g., credit card or utility company), getting an 
            advance from an employer, obtaining emergency assistance from 
            faith-based or community organizations, delaying purchases or 
            obtaining a small consumer loan, or using a bill payment 
            service such as BillFloat to pay a bill.  According to the 
            company, BillFloat "extend�s] your bill by up to 30 days, 
            helping protect your credit while avoiding late fees, 
            overdraft charges and expensive loans."
                                                                      



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             FDIC Small-Dollar Loan Pilot Program - a model for affordable 
            small loans   In addition, in February 2008 the Federal Deposit 
            Insurance Corporation (FDIC) began a two-year nationwide 
            "Small-Dollar Loan Pilot Program" under which participating 
            banks offered loans of up to $1,000; payment periods beyond a 
            single paycheck cycle; APRs below 36%; low or no origination 
            fees; streamlined underwriting criteria; and access to 
            financial education.  In many instances, the banks indicated 
            that loans could be processed in less than an hour.  The FDIC 
            indicated that the pilot, which ended at the end of 2009, was 
            a success and noted that "most pilot bankers indicated that 
            small dollar loans were a useful business strategy for 
            developing or retaining long-term relationships with 
            consumers.  . . .  The most prominent product elements bankers 
            linked to the success of their program were longer loan terms, 
            followed by streamlined but solid underwriting."  The 
            participating banks-with total assets ranging from $28 million 
            to nearly $10 billion-demonstrated that it can be profitable 
            to offer affordable small-dollar loans as an alternative to 
            costly products such as payday loans.

          Given the above arguably less expensive alternatives to a payday 
          loan, the Committee should consider whether this bill's 
          provision increasing the maximum value of a payday loan check 
          from $300 to $500 as discussed above would, in fact, aid 
          consumers struggling in the present economy or instead 
          contribute to a cycle of debt. 

          GIVEN THE ARGUABLY LESS COSTLY ALTERNATIVES TO A PAYDAY LOAN, 
          WOULD THIS BILL'S INCREASE OF THE LOAN LIMIT TO $500 IN FACT AID 
          CONSUMERS OR WOULD IT FURTHER EXACERBATE A CYCLE OF DEBT, AS 
          DISCUSSED ABOVE?

          4.  DOC report: policy options
           
          As noted in the Background, the December 2007 DOC report was 
          based upon a survey of payday lenders and DOC's annual report 
          for 2005-06.  That report included 22 recommendations, divided 
          into those intended to improve DOC's oversight of the industry 
          and those intended to strengthen its enforcement of the CDDTL.  

          In addition, DOC included a number of policy options for 
          consideration.  DOC noted that its policy options were "based on 
          the premise that the payday loan will be available to meet the 
          short-term emergency case needs of the consumers, while allowing 
                                                                      



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          for a longer-term installment product for those consumers that 
          are not able to pay back the full amount of the payday loan on 
          the due date and have sufficient funds remaining to pay their 
          normal living expenses."  The author notes that one of the 
          policy options suggested by DOC for further consideration was an 
          increase in the amount of the payday loan limit from $300 "to 
          another amount such as $500 or $750."

          In addition to this policy option, DOC also suggested the 
          following for further consideration:
           extend the term of a payday loan to 31 days (staff notes that 
            opponents to this bill suggest an amendment to the bill that 
            would implement this policy option); 
           prohibit a licensee from entering into a payday loan with a 
            borrower while that borrower had another payday loan 
            outstanding from any other licensee;
           make the payday loan origination fee a flat fee rather than a 
            percentage; 
           base the fees for payday loans on the loan amount on a sliding 
            scale;
           restrict a borrower from having a payday loan outstanding for 
            more than three months in the previous 12 months;
           require a payment plan with a minimum of six equal monthly 
            installments; and
           implement a database to track transactions 


           Support  :  California Financial Service Providers' Association; 
          California Hispanic Chambers of Commerce; Community Financial 
          Services Association 
           
          Opposition  :  AARP California; African American Network of Kern 
          County; Alliance of Californians for Community Empowerment; 
          Black Economic Council; California Association for Micro 
          Enterprise Opportunity; California Budget Project; California 
          Labor Federation - AFL/CIO; California Reinvestment Coalition; 
          California Rural Legal Assistance Foundation; California 
          Teamsters Public Affairs Council; Catholic Charities of 
          California United; Center for Responsible Lending; City of San 
          Diego; City and County of San Francisco; Coalition for Quality 
          Credit Counseling; Community HousingWorks; Community Legal 
          Services, East Palo Alto; Consumers Union; Council of Mexican 
          Federations; Dolores Huerta Foundation; East Los Angeles 
          Community Corporation; Greenlining Institute; Insight Center; 
          JERICHO; Honorable Jose Cisneros, Treasurer, City and County of 
          San Francisco; Korean Churches for Community Development; Latino 
                                                                      



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          Congreso; Los Angeles Metropolitan Churches; LULAC - CA Council 
          3120; 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; Santa Clara County Board of Supervisors; 
          Silicon Valley Community Foundation; The Americas Group; Ubuntu 
          Green; United Way of California; Western Center on Law and 
          Poverty 

                                        HISTORY
           
           Source  :  Author 

           Related Pending Legislation  :  SB 365 (Lowenthal) would clarify 
          that a payday lender may not issue a payday loan to a customer 
          if the customer already has a loan outstanding with any other 
          licensee.  The bill would also provide Legislative intent to 
          enact legislation that would authorize the Commissioner of 
          Corporations to contract with a third-party provider for the 
          implementation of a common database to aid in the enforcement of 
          the CDDTL.  This bill is in the Senate Banking and Financial 
          Institutions Committee. 

           Prior Legislation  :  

          SB 1146 (Florez, Ch. 640, Stats. 2010).  See Comment 2.

          AB 377 (Mendoza, 2009).  See Background. 

          AB 7 (Lieu, Ch. 358, Stats.  2007) authorized DOC to enforce, 
          under the CDDTL, federal protections related to payday loans for 
          members of the military and their dependents.  

          SB 898 (Perata, Ch. 777, Stats. 2002) enacted the Deferred 
          Deposit Transaction Law and shifted authority for its 
          administration to the Department of Corporations. 

          SB 1959 (Calderon, Ch. 682, Stats. 1996) expressly authorized 
          payday lending in California and gave regulatory authority to 
          the Department of Justice. 

           Prior Vote  :

          Senate Banking and Financial Institutions Committee (Ayes 5, 
          Noes 0)
          Assembly Floor (Ayes 49, Noes 16)
                                                                      



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          Assembly Appropriations Committee (Ayes 11, Noes 1)
          Assembly Banking and Finance Committee (Ayes 7, Noes 1)

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