Payday loan pricing

We estimate the pricing determinants for 35,098 payday loans originated in Colorado between 2000 and 2006, and generate a number of results with implications for public policy. We find evidence consistent with classical price competition early in the sample, but as time passed these competitive effects faded and the data become more consistent with a variety of strategic pricing practices. On average, loan prices moved upward toward the legislated price ceiling over time, consistent with implicit collusion facilitated by price focal points. Large multi-store payday firms tended to charge higher prices than independent single-store operators, but were less likely to exploit inelastic demand near military bases and in largely minority neighborhoods. Of the three loan pricing measures used in our analysis, the annual percentage interest rate (APR) favored by regulators and analysts performed poorly.

"Narrow Banking Reconsidered, The Functional Approach to Financial Reform"

Phillips presents the functional approach to reforming the financial system.This approach advocates the structural separation of the depository and lending functions of banks. As a result of such a separation, monetary and credit policy undergo a parallel separation, and government supervision and regulation of the banking industry are modified. The policy prescription developed within this approach is narrow banking, the creation of separate monetary and financial service companies with the elimination of or a substantial reduction in deposit insurance. Narrow banking not only meets the safety and soundness goals of bank regulation, but also maintains an institutional structure that accommodates market forces and technological innovation. He recommends the creation of monetary service companies that would serve strictly a payments function and would hold only safe assets and the establishment by the federal government of a mutual fund that holds only government securities as assets.

"A Path to Community Development, The Community Reinvestment Act, Lending Discrimination, and the Role of Community Development Banks"

The establishment of a system of federally regulated, for-profit, community development banks (CDBs) would help to fill the financial gap in areas inadequately served by traditional banks, requirements of the Community Reinvestment Act (CRA) notwithstanding. These organizations would be charged with delivering credit, payment, and savings opportunities and providing basic financing to households and small businesses in underserved areas. Such a system would not substitute for the CRA, but rather act as a supplement to current regulation. Proposed exemptions from CRA compliance for depository institutions that invest in the equity of a CDB would weaken the existing law by diluting the investment of the depository institution in its own particular community. Such proposals (under which "investment" has been defined to be as little as one-quarter of one percent of total assets) are not consistent with the spirit of the CRA and would negate the beneficial dialogue that takes place between the institution and the community in which it operates.

"An Alternative in Small Business Finance, Community-Based Factoring Companies and Small Business Lending"

According to Papadimitriou, Phillips, and Wray, at a time when small businesses are suffering from a credit crunch, "niche" financial institutions are filling the void left by more traditional sources of financing, such as commercial banks. The authors argue that the most important of these niche players are community-based factor companies, which are rapidly expanding from their client base in apparel and textiles to finance a range of firms in everything from electronics to health care. The purchase of accounts receivable by factors enhances the balance sheets of their clients, making it easier for the clients to obtain bank financing. Also, because factors are more interested in the creditworthiness of a client's customers than of the client itself, they are willing to extend loans in excess of collateral to rapidly growing businesses. Because factors are becoming an increasingly important source of financing for small and start-up businesses, the authors propose that factors be encouraged to play a broader role in financing firms in distressed communities by (1) making some factors eligible for funding and assistance under legislation regulating community development financial institutions and (2) by allowing investments by banks in factors to count toward compliance under the Community Reinvestment Act.

"The Community Reinvestment Act, Lending Discrimination, and the Role of Community Development Banks"

The Community Development Banks (CDBs) should not be seen as a substitute for the Community Reinvestment Act (CRA) or for other programs designed to revitalize lower income areas. Rather, they should be seen as a complement for existing programs and for other programs that will be proposed by the Clinton administration. As discussed above, the CRA process ensures that a dialogue takes place among regulators, financial institutions, and served communities: it ensures that banks identify their communities and that they satisfy some of the needs of these communities. Moreover, it helps to expand the awareness of bankers such that their expectations about presently undeserved areas are revised. It is unrealistic to expect that any financial institution can meet all the needs of any community; this, there is a role for a CDB to play in some communities that supplements the role played by traditional financial institutions. Similarly, while we believe that CDBs have an important role to play in revitalizing low income communities, we certainly do not see these as a substitute for the wide range of programs (both public and private) that will be needed to reverse long trends of deterioration experienced by some distressed communities. Finally, the CDBs are not intended to be welfare programs but to provide services to the community's residents, and consequently, they must meet the long-run market tests of profitability. Aside from the service aspect, community development banks will: (i)improve the well-being of our citizens not now served because of unresponsive, yet traditional loan qualification norms, and (ii) directly increase the opportunities for potential entrepreneurs and potential employees. The basic assumption underlying the community development bank is that all areas of the country need banks that are clearly oriented toward the small customer: households that have a small net worth, a small IRA account, and a small transactions account, and businesses that need financing measured in thousands rather then millions or billions of dollars.

"Community Development Banking, A Proposal to Establish a Nationwide System of Community Development Banks"

This brief proposes that the establishment of a nationwide system of community development banks (CDBs) would advance the capital development of the economy. The proposal is based on the notion that a critical function of the financial system is not being adequately performed by existing institutions for low-income citizens, inner-city minorities, and entrepreneurs who seek modest financing for small businesses. The primary goals of the CDBs are to deliver credit, payment, and savings opportunities to communities not well served by banks and to provide financing throughout a designated area for businesses too small to attract the interest of the investment banking and normal commercial banking communities.

The Regulation and Supervision of bank Holding Companies: An Historical Perspective

Scholars have generally concluded that the assigning of the BHC responsibilities to the Fed in 1956 was primarily based on the historical precedent of the Clayton Act and the Banking Act of 1933 which granted some powers to the Federal Reserve with respect to bank holding companies. This explanation is not sufficient because bank holding company bills had been introduced since 1930 and it is only after 1943 that the Federal Reserve is designated as the regulatory agency for BHCs. Why was there a change? There are three factors which together explain why the Federal Reserve was selected as the regulatory agency. The first, and probably most important, was in the legislative response to the public outcry over the abuses of bank affiliates. The bank affiliates and holding company issues were intertwined, and the outcome of the Banking Act of 1933 had important implications for the future regulation of BHCs. If the separation of commercial and investment banking had not occurred, the OCC would quite likely have been the regulatory agency for BHCs. It was recognized that a system of universal banking (national banks with addiliates) required a single regulator. Second, legislation proposed by Marriner Eccles and the Federal Reserve in 1943 to control BHCs specified the Federal Reserve as the regulatory agency, despite the fact that at the time there was little rationale for this. However, the bill introduced in 1943 became the BHCA of 1956. Third, the Comptroller of the Currency in 1956, Ray Gidney, believed that BHCs promoted efficiency in banking and needed little regulation. Those members of Congress who believed that BHCs should be tightly controlled, or abolished, had little incentive to entrust the regulation and supervision of BHCs to Gidney. If the comptroller of the Currency at the time had been a strong opponent of the expansion of BHCs, then there might have been reason to change the legislation. A reexamination of the reasons for granting regulatory power over BHCs to the Federal Reserve is of direct policy relevance today: Should we retain our multiagency regulatory structure if the U.S. moves toward some form of universal banking? The history of bank holding company regulation provides guidance in answering these questions.

"Community Development Banks"

The Clinton/Gore proposal for the creation of a network of 100 community development banks (CDBs) to revitalize communities is bold, and will contribute to the success of the U.S. economy. Banks are essential institutions in any community, and the establishment of a bank is often a prerequisite for the investment process. For this reason, the creation of banks in communities lacking such institutions is important to the welfare of these communities. The vitality of the American economy depends on the continual creation of new and initially small firms. Because it is in the public interest to foster the creation of new entrants into industry, trade, and finance, it is also in the public interest to have a set of strong, independent, profit-seeking banking institutions that specialize in financing smaller businesses. When market forces fail to provide a service that is needed and potentially profitable, it is appropriate for government to help create the market. Community development banks fall into such a category. They do not require a government subsidy, and after start-up costs, the banks are expected to be profitable. The primary perspective of this concept paper is that the main function of the financial structure is to advance the capital development of the economy-to increase the real productive capacity and wealth-producing ability of the economy. The second assumption is that capital development is encouraged by the provision of a broad range of financial services to various segments of the U.S. economy, including consumers, small and large businesses, retailers, developers, and all levels of government. The third is that the existing financial structure is particularly weak in servicing small and start-up businesses, and in servicing certain consumer groups. The fourth is that this problem has become more acute because of a decrease in the number of independent financing alternatives and a rise in the size distribution of financing sources, which have increased the financial system's bias toward larger transactions. These are assumptions that appear to be supported by the evidence: they are also incorporated in other proposals that advance programs to develop community development banking.

Community Development Banking: A Proposal to Establish a Nationwide System of Community Development Banks

Public Policy Brief No. 3, Levy Economics Institute of Bard College