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January 29, 2007
Critique of Fed study on predatory payday loans available
The Center for Responsible Lending has published a critique of major analytical flaws in a new working paper Defining and Detecting Predatory Lending on payday loans by Federal Reserve economist Donald P. Morgan of the Federal Reserve Bank of New York. The Fed paper comes to the preposterous conclusion that while payday lending is "expensive," it is not "welfare-reducing" and therefore not "predatory." I had a premonition that this paper would contain such out-of-step findings when the first reference I saw to it was a laudatory pre-publication tease, with excerpts, on a rent-to-own industry website. From the Center for Responsible Lending critique:
Morgan's findings are flawed for three key reasons:
The analysis contains fundamental errors in its characterization of which states allowed payday lending. Example: Morgan identifies North Carolina--which had at least 500 stores during the analysis period--as a non-payday lending state. Key definitions utilized by the research are overly narrow or are contradicted by available data. Example: Morgan, in part, defines vulnerable households as those with unpredictable future income. However, an industry survey notes that households are nearly three times likely to borrower payday loans because of unexpected expenses.Morgan's finding that unlimited payday lending leads to lower prices is flatly contradicted by other research. Example: Researchers from the FDIC, using a national, random sample, found that most payday companies charge the maximum rate permitted by state law. Interestingly, when I was looking for that rent-to-own industry link above, I also found an article on how the industry is "successfully" using remote software that shuts down rental computers when the customer misses a payment. I've written on Digital Rights Management and Spyware systems; this is one more example of a system of control imposed on "digital consumers." These may seem reasonable and efficient to some, especially on a case-by-case basis, but when you look at the impact of all of these digitally-enabled systems that track consumers and even restrict or control their use of products or services, it raises many questions I intend to discuss in future posts.
Posted by Ed Mierzwinski at January 29, 2007 06:30 AM
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