- 1 DROM Fringe Finance Products
- 1.1 FRINGE FINANCE CREDIT PRODUCTS AND SERVICES: CREDIT FOR THE PRECARIAT
- 1.2 PAWNSHOP AND AUTO TITLE LOANS
- 1.3 RENT-TO-OWN STORES
- 1.4 REFUND ANTICIPATION LOANS (RALS)
- 1.5 SURVIVAL STRATEGIES
- 1.6 RESOURCES
DROM Fringe Finance Products
FRINGE FINANCE CREDIT PRODUCTS AND SERVICES: CREDIT FOR THE PRECARIAT
Wall Street bankers have always tried to distance themselves from the taint of loan-sharking and other fringe financial services. For most, non-bank lending still conjures up images of dilapidated storefronts on the edge of town, surrounded by vice and petty criminality. But if you're one of the 12 million Americans who took out a payday loan in the past year, it's more likely that you did it in a suburban strip mall or cyberspace. It's even possible that you got it from a bank-five large banks, including Wells Fargo, have begun to offer payday loans.
Although they seem to be worlds apart, in reality these markets are interconnected and overlapping; the biggest players in all segments of fringe finance are publicly traded, national corporations. Today, around 20% of all users of "alternative" financial services (AFS) also use traditional banks. Whether sourced in prime credit or subprime, student loans or pawn loans, the profits of our indebtedness flow to the 1%.
But the 99% is waking up to the bait-and-switch. This chapter covers the debt traps encountered outside of the federally insured financial institutions: AFS credit products and services such as payday loans, pawn loans, auto-title loans, "rent-to-own" agreements and refund anticipation loans (RALs). Like traditional banks, these businesses provide ready access to cash and/or credit. However, their services are substantially more costly than those typically offered by major banks, and they frequently involve even more unfair, abusive and deceptive practices. Enabled by government at all levels, the poverty industry preys on the poor. For a long time the working poor have been its main target, but the Great Recession has supplied millions of new marks: people with busted credit, people who are desperate for cash and people who have fallen from the ranks of America's disappearing middle class. At a time of unprecedented inequality, poverty and precarity, unprincipled money lenders are poised to make a killing; stealing from people who have nothing means indebting them, possibly for life.
During the 1990s, deregulation tore through every segment of the U.S. financial system. Lending standards were loosened, increasing the availability of credit on Main Street as well as Malcolm X Boulevard. The resulting proliferation of high-cost subprime loans was celebrated as the "democratization of credit." The rolling back of core financial consumer protections created an unprecedented opportunity for financial extraction-the prospect of making money off of people who have no money. On the fringes of finance, money comes easy, but debts are built to last.
Given the state of household finances, rising demand for "Quick Cash, Few Questions Asked!" should come as no surprise. Having maxed out their credit cards and bank credit lines, people increasingly rely on AFS providers. Most AFS borrowers are unbanked, which includes about 20% of African Americans and 20% of Latino/as. But now 21 million borrowers are "underbanked," meaning they use AFS in combination with traditional banking services.
About half of AFS users have incomes below the poverty line. This means that a large percentage of the customer base of the so-called "poverty industry" is not poor. In fact, it's quite possible that many of the underbanked not too long ago qualified for prime mortgages and boasted incomes considerably higher than the national median. These are sure signs of precarity: insecure and unpredictable living conditions, which harm material or psychological welfare.
Compared to traditional bank loans, fringe lending has its own peculiar set of tricks and traps. But like any extension of credit, it involves a set of expectations about the future. When we sign on the dotted line, we're assuming that things will get better, that our financial situation will improve enough to make repayment possible. Lenders exploit borrowers' dreams. In fringe finance, the aspirations are simpler and more immediate, like having a way to get to work, buying groceries for your kids, bailing your cousin out of jail or treating your aging mother to lunch on her birthday.
PAYDAY LOANS: HOW SHORT-TERM LOANS BECOME LONG-TERM DEBTS
Nearly half of workers in the United States report living "paycheck-to-paycheck." In other words, at least 60 million of us are one setback away from economic ruin. After years of insufficient income, we've drained our savings just to cover necessary expenses. Those of us who've never been able to accumulate savings already depend on short-term credit to get by. In other words, we've gone into debt in order to live.
In the early 1990s, there were fewer than two hundred payday lending stores in America. Today there are 23,000-more than McDonald's-making payday lending a $50 billion industry. The deregulation of interest rates at the end of the 1970s, which removed all caps and limits on interest, set the stage for the "rise of payday." Today, fifteen large corporations, which together operate roughly half of all loan stores, dominate the industry. Of these fifteen, six are publicly-traded companies: Advance America, Cash America, Dollar Financial, EZ Corp, First Cash Financial, and QC Holdings.
Having witnessed the rapid and socially destructive effects of these loans, fifteen states have renewed consumer protections and rolled back authorizations of payday loans, eliminating payday loan storefronts. Another eight states have limited the number of high-cost loans or renewals that lenders may offer. The reforms' effectiveness, however, has been limited by the advent of unlicensed online payday lending, which now comprises 35% of the market and allows for even more egregious practices.
The appeal of payday loans is the flip side of the barriers to traditional banking: convenience, ease of transaction and few questions asked. Payday loans are small-credit loans marketed as a quick and easy way to tide borrowers over until the next payday. However, the typical storefront payday loan leaves borrowers indebted for more than half of the year with an average of nine payday loan transactions at annual interest rates over 400%. And if you think that's bad, try 800-1,000% APR in the case of online payday loans.
Make no mistake: payday lending is legal loan-sharking. The aim is to prolong the duration of debt in order to extract as many fees as possible; this is known as "churning," and doing this every two weeks makes up 75% of all payday loan volume. Typically, payday loan debt lasts for 212 days. Repeated payday loans result in $3.5 billion in fees each year.
Payday loans are carefully structured to bring about this result. The catch is the "balloon payment," a well-known predatory practice. When you take out a payday loan (normally $100 to $500), you put down collateral (e.g., a postdated check or electronic access to your bank account) equal to the loan amount plus a fee ($15 to $35 per $100 borrowed). At the end of the typical two-week loan period, you either repay the total owed or renew the loan for another two weeks. Few borrowers (only 2%) are able to make the balloon payment, so instead they pay only the fee and renew the loan, which grows in size due to compound interest.
With every renewal, the "balloon" grows bigger, making repayment ever more difficult. In the meantime, the lender goes on extracting fees every two weeks, and pretty soon, you've repaid the amount of the original loan (the principal), yet you are forced to continually renew the loan until you can repay the hugely inflated balance in one lump sum. According to the Federal Trade Commission, a number of online lenders obtain borrowers' bank account information in order to deposit funds and later withdraw the repayment, with a supposed one-time fee. In actuality, withdrawals occur on multiple occasions, with fees each time. The FTC cites a typical example where someone borrowed $300 and, after the lender withdrew many times, the borrower was ultimately expected to pay $975. As you can see, with payday loans, the term "debt trap" takes on a whole new meaning.
The payday industry lobby group, which misleadingly calls itself the Community Financial Services Association (CFSA), tries to get some cover for its predatory behavior by warning, "Payday advances should be used for short-term financial needs only, not as a long-term financial solution." In actuality, the vast majority of borrowers (69%) use payday loans for everyday expenses, just to get by. A recent Pew survey shows that only 16% of borrowers actually used them in emergencies. All of the evidence consistently shows that borrowers do not use this hazardous product as prescribed and thus endanger their financial lives. This amounts to financial malpractice.
Still, 12 million Americans have used payday loans over the past year. And who can blame them? If you have lousy credit and need cash fast, a short-term, no-credit check loan seems like a lifeline, just like the ads promise. No doubt, the loans offer short-term relief, but in exchange for long-term financial harm. According to the CFSA, "payday advance customers represent the heart of America's middle class." This particular industry talking point has truth to it. The core market for payday loans are people with regular incomes and/or bank accounts who are expected to "secure" their loans with pay stubs, benefit stubs, or personal checks-that is, the growing class of the underbanked.
A recent survey of payday loan users conducted by the Pew Center finds that most borrowers are white, female and from twenty-five to forty-four years old. However, certain groups disproportionately use payday loans: those without a four-year college degree, home renters, African Americans, those earning below $40,000 annually and those who are separated or divorced.
People of color are targeted for exploitation by payday lenders and fringe finance more broadly. Like other forms of AFS, the immense expansion of payday lending has overwhelmingly taken place in communities of color. In California for example, Black people are more than twice as likely as whites to live within one mile of at least one payday lender. The CFSA and leading payday lenders have for years cultivated relationships with Black leaders and organizations-lawmakers, celebrities, elders of the civil rights struggle- as part of their lobbying and marketing campaigns. "Just like they target minority groups to sell their products, they target minority groups to make their products look legitimate," says critic Keith Corbett, executive vice president of the Center for Responsible Lending. Contrary to claims that payday lending represents the "democratization" of credit, the kind of credit payday lenders are selling leads only to cycles of ever-growing debt.
With payday lenders you are dealing with the worst of the worst. These are people who know they are charging rates of interest that ought to be illegal, that used to be illegal, that have always been illegal in just about every other country that has ever existed in the world. While it is best to avoid payday loan officers entirely, when dealing with one, it is important to remember: this person knows that what they are doing is wrong. If they have any human decency, they are secretly wracked with guilt; even if they don't, they are terrified that the world will figure out what they are really up to and recognize it as a criminal activity, since that's what it really ought to be.
If you have outstanding debt with a payday lender, remember: o Payday loans are unsecured debt. This is any type of debt or general obligation that isn't collateralized by a lien on specific assets, like a house or car. In the event of default, the lender has no legal claim on your assets, no matter what the debt collectors say. o Many people default, and expectations of that outcome are built into the business model. The typical "risk premium" (the cost increase required to compensate for credit risk) is so high that even with 15-20% default rates, payday lenders are highly profitable. o In the event of default, lenders' only means of retaliation is to report the event to a credit agency. They commonly try to persuade borrowers that repayment of payday loans strengthens credit-the industry even funds research to peddle this myth-but it's not true. Reports of any transactions with payday lenders will harm your credit. And if you're taking out one of these loans, odds are your credit is already damaged.
HOW TO DEFAULT ON A PAYDAY LOAN
It should go without saying that executing the following plan is high risk. Think and act carefully!
1. Take out a loan with an online payday lender. Create a new email address and obtain a prepaid cell phone; use that information on the application. For extra protection, use a computer at the library. If there is a call center that wants to talk to you, get someone else to speak since they might record your voice. 2. When you sign up for a payday loan, you enter into an agreement between yourself and the provider that they have the right to take money from your bank account or charge your debit card automatically when your due date arrives. Only give them the right to one specific bank account or debit card. 3. Wait until they decide to debit you. Then call them up, ask why you were charged and tell them that you never filled out this application for a loan. Granted, this argument is more difficult if you used a payday loan before; you want to make it seem as if your financial situation is good enough that you don't need one. 4. If you keep fighting, they will refund you. Fraud happens all the time on the internet, so your claims are perfectly plausible. If they persist, say that you're going to call the relevant regulatory agencies. Many times they will cave in because most online payday loan companies do not want to get the government involved.
If this works, then you're in the clear! You get free money, your credit score is unharmed and debt collectors will not harass you. However, payday loan providers might not believe you and keep charging you the outrageous rates. To default: If you choose to pay via bank account transfers, then move all of your funds from that bank account to other accounts. If you choose to pay via debit card, then cancel the debit card.
The most annoying thing is that you'll have to deal with debt collectors. This is why it is essential that you don't supply your actual phone number or email address; that way, they'll just send you direct mail, which you can always throw away. If they have your actual phone number or email address, they will harass you to no end, in which case just keep ignoring them. They are trained liars. (For more advice on dealing with debt collectors, see Chapter IX.) The following information comes from an anonymous former payday loan employee:
How to Destroy The PayDay Loan Industry
1. Identify a group of people planning to move between any of the four countries: United States, Canada, England, and Australia. Have each person take out a number of payday loans. 2. Once you get about $10,000 in loans, move the money to different bank accounts so the companies don't have access to it. 3. When you move to another country, your credit score will be a blank slate and you'll have free money to fight the system. 4. With about a thousand people willing to travel between the four countries, you can take out a few major international pay loan providers, like Wonga and Enova Financial.
PAWNSHOP AND AUTO TITLE LOANS
Unlike payday loans, a pawnshop loan is when a borrower gives property to a pawnbroker to secure a small loan. The loan is generally for one-half of the item's value. If the borrower is able to repay the loan with interest by the due date-typically between one and three months-then the item can be retrieved. The average pawnshop loan is for $70, and approximately one out of every five pawned items are not redeemed. According to a survey by Think Finance, approximately one-quarter of eighteento thirty-four-year olds who are unor underbanked use pawnshops. Because U.S. citizenship and regular income are not required for pawn loans, they are particularly appealing to undocumented immigrants and others who might have difficulty obtaining loans through traditional financial services. Ten states do not require any cap on monthly interest rates and forty states do not require the return of pawned items.
A car-title loan is a similar product to a pawnshop loan, but even more egregious-so much so that it is prohibited in thirty-one states. A borrower in this case exchanges the title to their automobile for cash. The vehicle can still be driven, however. Typically the loan is for about one-quarter of the vehicle's value. If it is not repaid with interest within thirty days, the lender could repossess the car or extend the loan for thirty more days and add further interest. When annualized, the rate of interest for title loans is in the triple digits, and often exceeds 900%.
LoanMax, an auto-title lender for which Reverend Al Sharpton of all people did a television commercial, says its average loan is $400.22 Suppose you take a $400 title loan from them. Thirty days pass and you can't pay the $520 you now owe. Instead of repossessing your car, the gracious lender decides to renew the loan. And then again. And again. Title loans are renewed on average eight times per customer. Therefore, within a typical timeframe, you may end up owing nearly three-and-a-half times what you originally borrowed!
Having property repossessed and incurring further debt are the tragic yet predictable consequences of obtaining a loan through pawning. Payday loans and other examples laid out in this chapter are no better. The information provided above offers a glimpse of how these loans dig people into deeper desperation. Despite state regulations such as APR caps, these alternative financial services are inherently predatory and cannot be modified to be substantially less harmful to borrowers. Pawnshop loans and car-title loans should be avoided at all costs.
However, so long as viable alternatives remain inaccessible to those typically targeted by such institutions-traditionally low-income communities of color, but increasingly Millennials of all backgrounds-the problem will remain and intensify. At the conclusion of this chapter, we contemplate a handful of suggestions for obtaining cash without having to be on the receiving end of predatory lending practices.
Rent-to-own (RTO) lenders offer appliances, electronics and other items which, as the name suggests, people can eventually own. This is different from credit purchases where the customer immediately gains the title to the product. Aaron's and Rent-A-Center are two of the biggest such companies; their mascots are a self-proclaimed "lucky" dog and Hulk Hogan respectively. On both company websites, product prices are not listed; you must provide some personal information, such as the last four digits of your Social Security number, in order to even receive a quote. Aaron's explicitly states that their stores are "strategically located in established working class neighborhoods and communities," which is a euphemism for exploiting poor people and people of color. This predation is also unabashedly reflected in RTO companies' own annual reports. Despite having fewer than half the number of customers as payday lenders, the RTO industry generates a similar revenue. What accounts for high sales?
Unsurprisingly, there's a whole host of fees when using RTOs. Charges often include "security deposits, administrative fees, delivery charges, 'pickup payment' charges, late fees, insurance charges, and liability damage waiver fees." These costs are generally not revealed to customers. Less than a third of U.S. states require disclosure of the total cost to own, and even then, many of these aforementioned charges are underestimated. With all of that on top of an average APR around 100%, consumers typically pay between two and five times more than if they had purchased the same item at a retail store. On average, RTO customers spend an extra $700 a year. Failure to pay in full, or defaulting, results in the repossession of the product and loss of any money previously put toward the item. Only eleven states require any cap whatsoever on the price of products or APR at RTO lenders.
Items available at rent-to-own stores are readily available elsewhere, in some instances for one-fifth of the price; however, this may require saving up until one can afford the retail value rather than resorting to paid installments. If you need a computer, for example, consider borrowing one or using one at the library until you can pay for it at a not-so-predatory store. It also might mean being willing to relinquish a bit of luxury and buy items secondhand. Either way, it ultimately beats the pitfalls of RTO lenders.
There are also many items that you can simply obtain for free, although it may require waiting for just the right moment and taking time to do some research. Websites like the Freecycle Network (freecycle.org) and the free section on Craigslist (craigslist.org) have made this process much more convenient and accessible.
REFUND ANTICIPATION LOANS (RALS)
Refund Anticipation Loans (RALs) are yet another type of loan to exploit the unbanked and underbanked. For the lender, the profits are high and the risks are low. Many tax preparation companies offer this service. For those expecting much-needed cash from a tax refund but who cannot wait several weeks for it, an RAL is an appealing quick solution. A taxpayer can receive the full amount of their anticipated tax refund sometime between two minutes and two days. Like other fringe finance loans, RALs have a triple digit APR.
Suppose you're expecting a tax refund that approximates the average in the United States in 2011, which was $2,193. Rather than wait to receive the refund, you take out an RAL at a tax preparation company. In six weeks, you receive your refund and at this point, assuming the APR is "only" 200%, you'll need $728.25 in addition to your refund in order to pay back your loan. With a bank account, your tax refund could be deposited directly in less than two weeks, but of course that's not an option for the unbanked. Filing taxes online, if possible, expedites the receipt of one's refund. This approach may meet the needs of those requiring cash in the immediate present without having to lose so much money in the long run; however, receiving a refund check presents its own problems if you don't have a checking account (see the section on CCOs in Chapter VII).
Another approach is to attempt avoiding having a tax refund at all. Until you find institutions in your neighborhood lending money free of charge to you, why should you in essence lend to the IRS at 0% APR? Instead of getting a large sum once a year in the form of a tax refund, you can spread that amount out amongst your paychecks. This requires adjusting your withholdings on your W-4. If you don't have investments or itemized deductions, it would be simple to calculate how many exemptions you should claim in order to avoid a tax refund without getting a liability. Regardless of how many dependents you have, you can still claim, for example, five dependents for planning purposes. (When filing taxes, you would legally need to write the actual number of dependents.)  Many websites, including the IRS website, feature a withholding calculator to help you make a more informed decision about this approach.
Throughout the last two chapters, several strategies have been raised for avoiding or beating the various institutions that offer fringe finance. These chapters have been written with the understanding that viable alternatives are hard to come by in many areas. In the course of doing research, we have often found that the recommended alternative to one segment of the fringe finance industry is frequently another segment. For example, in warning against the dangers of refund anticipation loans, the suggestion is often to instead obtain a prepaid debit card.
We have to work together toward rendering all such institutions obsolete, toward a situation where people can have basic needs met without immense sacrifice. Notably, at least one-quarter of unbanked households in the United States do not use any fringe finance products or services. That is, over two million households are getting by without a checking account, without subprime loans, without cashing checks at CCOs, and without pawning their items. These households in particular have experiences worth sharing and learning from. It is our desire that others reading this manual can provide their own strategies, which can be compiled and included in later editions.
The unbanked and underbanked can in certain instances avoid subprime loans. This may mean asking to borrow from friends or family, seeking emergency community assistance, and, if an option, asking your employer for advanced payment. Selling unwanted items on Craigslist or at thrift stores and consignment shops is a more reliable source of cash than pawning. Moreover, it's important to consider what you need the money for in the first place. Is there an alternative at a cheaper price, or perhaps a free alternative even? Will buying something secondhand suffice? Is it worth obtaining something immediately if it means paying more?
While these questions are important for individuals to contemplate in order to avoid or minimize the harm done by AFS providers, we must go deeper. The Debt Resistors' Operations Manual, after all, is about collective action and radical transformation.
While they may be designated as "fringe," the payday loan companies, the rent-to-own stores, the pawnshops and the check cashing outlets are all central to the debt landscape we are describing in this manual. We must come together to work toward the eradication of these venal institutions while creating better ways of obtaining what we need.
Financial justice research and advocacy for low-income and underrepresented communities: Center for Responsible Lending (responsiblelending.org) Consumer Action (consumer-action.org) The Consumerist (consumerist.com) Consumers Union - Defend Your Dollars (defendyourdollars.org) LawHelp.org National Consumer Law Center (nclc.org) Neighborhood Economic Development Advocacy Project (NYC) (nedap.org)
For filing complaints and reading complaints of other consumers: Consumer Protection Financial Bureau (consumerfinance.gov/complaint) Ripoff Report (ripoffreport.com)
ARTICLES AND BOOKS
The Brookings Institution, The Higher Prices Facing Lower Income Customers, August 18, 2006 (tinyurl.com/DROMBrookings). Candice Choi, "Reporter Spends Month Living Without a Bank, Finds Sky-High Fees," Huffington Post, December 11, 2010 (tinyurl.com/DROMChoi). Sharon Hermanson and George Gaberlavage, The Alternative Financial Services Industry, AARP Public Policy Institute, August 2001 (tinyurl.com/DROMHermanson). Dick Mendel, "Double Jeopardy: Why the Poor Pay More," National Federation of Community Development Credit Unions, February 2005 (tinyurl.com/DROMMendel). Federal Deposit Insurance Corporation, National Survey of Unbanked and Under-banked Households, December 2009 (tinyurl.com/DROMFDIC02). Gary Rivlin, Broke USA: From Pawnshops to Poverty, Inc., How the Working Poor Became Big Business, (New York, NY: HarpersCollins, 2010). "The Truth About Immigrants' Banking Rights," NEDAP (tinyurl.com/DROM-NEDAP03). John Ulzheimer, "Are Pawn Shops, Rent-to-Own and Other Loan Alternatives Worth It?" Mint Life, January 30, 2012 (tinyurl.com/DROMUlzheimer).
Regina Austin, "Of Predatory Lending and the Democratization of Credit: Preserving the Social Safety Net of Informality in Small-Loan Transactions," American University Law Review, 53, no. 1217, (August 2004) (tinyurl.com/DROMAustin). Nick Bourke, Alex Horowitz, and Tara Roche, Payday Lending in America: Who Borrows, Where They Borrow, and Why, Pew Charitable Trusts, July 2012 (tinyurl.com/ DROMBourke). Daniel Brook, "Usury Country: Welcome to the Birthplace of Payday Lending,"Harper's, April 2009 (tinyurl.com/DROMBrook). "Give Me a Little Credit: Short-Term Alternatives to Payday Loans," Cash Net USA, March 2012 (tinyurl.com/DROMCashNet). Stephanie Mencimer, "Civil Rights Groups Defending Predatory Lenders: Price-less," Mother Jones, August 1, 2008 (tinyurl.com/DROMMencimer).
Pawnshop and auto title loans Christopher Neiger, "Why Car Title Loans Are a Bad Idea," CNN, October 8, 2008 (tinyurl.com/DROMNeiger). "Title Loan: Don't Risk Losing Your Car," Center for Responsible Lending, 2011 (tinyurl.com/DROMCRL). Valerie Williams, "Auto Title Loans: Are They the Best Alternative for Fast Cash?" Suite 101, September 2, 2010 (tinyurl.com/DROMWilliams).
"Alternatives to Rent-to-Own Shopping," Consumer Reports, June 2011 (tinyurl.com/DROMConsumer01).
Refund anticipation loans (RALs)
William Perez, "Adjusting Tax Withholding from Your Paycheck," About.com (tinyurl.com/DROMPerez).
1. "Bank Payday Lending: Which Banks and Where?" Center for Responsible Lending, 2011 (tinyurl.com/DROMCRL2). They call them "direct deposit loans," but don't be fooled; they're just as bad. 2. Regina Austin, "Of Predatory Lending and the Democratization of Credit: Preserving the Social Safety Net of Informality in Small-Loan Transactions," American University Law Review 53, no. 1217, August 2004 (tinyurl.com/DROMAustin). 3. Federal Deposit Insurance Company, 10. 4. Jacquelyn Smith, "New Survey Finds Fewer Workers Living Paycheck-To-Pay-check This Year," Forbes, August 15, 2012 (tinyurl.com/DROMSmith). 5. Nathalie Martin, "Online Payday Lenders Seek More Respect and Less Oversight: Call Them What You Like, They are Still 1,000% Long-Term Loans," Credit Slips, July 26, 2012 (tinyurl.com/DROMMartin). 6. "Fast Facts: Payday Loans," Center for Responsible Lending (tinyurl.com/DROM-CRL3). 7. "Fast Facts: Payday Loans." 8. "Fraudulent Online Payday Lenders: Tapping Your Bank Account Again andAgain," Federal Trade Commission, April 2012 (tinyurl.com/DROMFTC02). 9. Bourke, Horowitz, and Rouche, 5. 10. Daniel Brook, "Usury Country: Welcome to the Birthplace of Payday Lending,"Harper's, April 2009 (tinyurl.com/DROMBrook). 11. Bourke, Horowitz, and Rouche, 5. 12. William C. Apgar, Jr. and Christopher E. Herbert, U.S. Department of Housing and Urban Development, Subprime Lending and Alternative Financial Service Providers: A Literature Review and Empirical Analysis (Washington, D.C.: GPO, 2006) (tinyurl. com/DROMApgar), I-41. 13. Stephanie Mencimer, "Civil Rights Groups Defending Predatory Lenders: Priceless," Mother Jones, August 1, 2008 (tinyurl.com/DROMMencimer). 14. Mencimer. 15. The content in this section is modified from: Anonymous payday loan insider, e-mail to author, July 29, 2012. 16. "Give Me a Little Credit: Short-Term Alternatives to Payday Loans," Cash Net USA, March 2012 (tinyurl.com/DROMCashNet), 2. 17. Sharon Hermanson and George Gaberlavage, The Alternative Financial Services Industry (Washington, D.C.: AARP Public Policy Institute, 2001) (tinyurl.com/ DROMHermanson), 2. 18. "Millennials Use Alternative Financial Services Regardless of their Income Level," Think Finance, May 17, 2012 (tinyurl.com/DROMThink). 19. Signe-Mary McKernan, Caroline Ratcliffe, and Daniel Kuehn, Prohibitions, Price Caps, and Disclosures: A Look at State Policies and Alternative Financial Product Use (Washington, D.C.: The Urban Institute, 2010) (tinyurl.com/DROMMcKernan), 6. 20. "Title Loan: Don't Risk Losing Your Car," Center for Responsible Lending, 2011(tinyurl.com/DROMCRL). 21. Hermanson and Gaberlavage, 7. 22. Howard Karger, "Swimming With the Sharks," AlterNet, January 10, 2006 (tinyurl.com/DROMKarger). 23. "Title Loan: Don't Risk Losing Your Car." 24. Think Finance. 25. Jim Hawkins, "Renting the Good Life," William and Mary Law Review, 49, no. 6. 2008 (tinyurl.com/DROMHawkins), 2059. 26. Rivlin. 27. Hermanson and Gaberlavage, 2. 28. Rivlin. 29. John Ulzheimer, "Are Pawn Shops, Rent-to-Own and Other Loan Alternatives Worth It?" Mint Life, January 30, 2012 (tinyurl.com/DROMUlzheimer). 30. McKernan, Ratcliffe, and Kuehn, 6. 31. Christine Dugas, "Tax Refunds Being Used to Pay for Bankruptcy Filings," USA Today, April 13, 2012 (tinyurl.com/DROMDugas). 32. Anonymous accounting insider, e-mail to author, August 20, 2012. 33. Federal Deposit Insurance Company, 29.