HomeMy WebLinkAboutItem 06 - Pay Day Lending MEMO TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: BRUNO RUMBELOW, CITY MANAGER 63
MEETING DATE: DECEMBER 5, 2017
SUBJECT: PAY DAY LENDING - PRESENTATION
Shonda Schaefer, Executive Director and Stacy Pacholick, Director of Programs for
GRACE will make a presentation about the concerns surrounding pay day lending
establishments in Grapevine.
BACKGROUND:
GRACE, local churches and other organizations serving residents of Grapevine and the
surrounding Metroplex are coming together to ask for a local ordinance to reduce the
negative impact of pay day and auto-title lenders. Further, they have asked for time on
your agenda to explain this issue. There are four establishments like this in Grapevine.
Currently, there are 40 other Texas cities that have adopted ordinances to reduce the
lending practices in their local communities.
BR/sgp
Dear Grapevine City Council ..
I/1 \11 ,
As the leaders of the commle 11Iunity serving residents of the Metroplex, including
Grapevine, we come together to ask you to take action by adopting an ordinance to
' GRACE reduce the negative impact of payday and auto-title lenders.
"Giving as we have received We have heard over and over again that these loans hurt our clients and parishioners by
to help those In need."
exacerbating their already desperate financial circumstances through their exorbitant
' Don Johnston,President fees—generally more than 400%in APR. Frequently the high costs lead to further
Whites Chapel United MethodistChurch financial distress for borrowers. In 2014,more than 845 cars were repossessed each
Traci Bernard,RN week in Texas by auto title lenders. Loss of transportation can mean loss of
Vice-President of Development
Texas Health Hospital Southiake employment further compounding a desperate situation.
Mark Moyer
Vice-President uPrograms
Crown of Life Lutheran Church The Office of Consumer Credit Commission reports that more than$345 million was
Randy Robbins,M.D. loaned at the 496 payday and auto-title loan storefronts in the Dallas-Plano-Irving
Vice-President of Capital Campaign Metropolitan Division in 2014. Borrowers paid more than$263 million in fees and
Gateway Church
$427,854,383 in refinances. Therefore,we can estimate that more than$2.7 million
Carita Weaver
Vice President of Facilities was loaned at Grapevine's four payday and auto-title loan locations,with
i5 web works borrowers paying more than $2.1 million in fees. These locations divert critical
Paul Bischler business tax revenue away from our city, at approximately$175,000 in sales tax
Treasurer
BNSF Railway revenue each year.
Bree Vopelak
Secretary/Vice-President of Human Resources To date,40 cities in Texas-including our neighboring cities of Dallas,Arlington,
Hamilton Vopelak,P.C.
John Elleson,Ex officio Mesquite,Flower Mound, Garland, Hurst, Euless, and Bedford-have adopted an
The Church of Jesus Christ of Latter day Saints identical ordinance to provide basic protections to borrowers and limit the most
Shonda Schaefer predatory practices of the payday and title loan industry. We see that payday and auto-
GRACE Executive Director title lenders are directing customers to loan locations in Grapevine since the city does
Larry Darlage,Ph.D. not yet have this ordinance. Therefore, it is of importance for your residents and the
Crown of life Lutheran School h
image of our community that the City of Grapevine adopts this ordinance.
John Fletcher
Fletcher Consulting
Jennifer Hibbs Also, as people of faith,we believe usurious lending is a matter of morality and human
City of Grapevine dignity. Lending designed to create profit by trapping people in never-ending loans
Jeanne Michalski displays a stunning lack of respect for the humanity of the borrower and takes
Community Representative
advantage of unfair market competition.
Mike Mills
White's Chapel United Methodist Church
Duff O'Dell Collectively we urge you to please protect our family and friends by adopting TML's
Good Shepherd Catholic Community model payday ordinance. Please know that if you choose to make a stand,members of
Karen Parrish the faith community will stand by you.
Community Representative
Tommy Pennington Sincerely,
Tommy Pennington Realty Group
Sean Shope
First Financial Bank Faith in Texas and GRACE
Becky St.John
GCISD Board of Trustees
John Terrell Shonda Schaefer
COMM Mayor,City of Southlake
Executive Director, GRACE, Grapevine, Texas
Felix Vasquez,Jr.
Hyphen Solutions,ICC
Th,GRACE Mi.sinn
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Rev. John Mollet
Senior Pastor,First United Methodist Church, Grapevine, Texas
Ross Sawyers
Lead Pastor, 121 Community Church, Grapevine, Texas
Rev Dara Austin
Pastor for Faithworks Mission and Outreach, White's Chapel UMC, Southlake, Texas
Rev. Richard Eldredge, T.O.R.
Pastor,Good Shepherd Catholic Community, Colleyville, Texas
Scott Allen
Senior Minister, Grapevine Church of Christ, Grapevine,Texas
Dr. Rob Maupin
Missions Pastor, Compass Christian Church, Colleyville, Texas
Doug Page
Senior Pastor, First Baptist Church, Grapevine,Texas
Rabbi Charlie Cytron-Walker
Rabbi, Congregation Beth Israel, Colleyville,Texas
Rev. James Flynn
Pastor, St. Francis of Assisi Catholic Church, Grapevine,Texas
Clayton Reed
Lead Pastor, Southlake Baptist Church, Southlake,Texas
James Morris
Pastor, Gateway Church, Southlake, Texas
Rev. Wes Helm
Lead Organizer, Faith in Texas
Rev. Edwin Robinson
Managing Director, Faith in Texas
Dr. Lydia Bean
Executive Director, Faith in Texas
Dr. Terrence Autry
Pastor, Christ Community Church, Richardson, Texas
•
:.
Rev. Eric Folkerth
Senior Pastor,Northaven United Methodist Church, Dallas, Texas
Mahlon Hight
Minister of Congregational Life,Northaven United Methodist Church, Dallas, Texas
Rev. Dr. Owen K Ross
Pastor, Christ's Foundry United Methodist Mission
Rev. Dr. C. Dennis Williams
Pastor, Smith Chapel African Methodist Episcopal Church
Chair of Religious Studies,Paul Quinn College
Rachel Triska
Executive Director, Life in Deep Ellum
Dr. Kimberly Allen
Minister of Christian Education, Community Missionary Baptist Church
Francene Adger
Director of Assimilation and Community Relations, Community Missionary Baptist Church,
DeSoto,Texas
Rev. Charlie Brown
Senior Pastor, The Crossing Baptist Church, Mesquite, Texas, DeSoto,Texas
Rev. Marcus D. King
Senior Pastor, Disciple Central Community Church,DeSoto, Texas
Rev. Kwesi R. Kamau
Lead Pastor, Impact Church DFW,Carrolton, Texas
Rev.James Minor
Senior Pastor, Glen Oaks UMC, Dallas, Texas
Rev. Daniel Young
Senior Pastor,Newsong Dallas, Richardson, Texas
Rev. Becky Hensley,
North Texas Conference UMC, Board of Church and Society
Pastor Gregory L. Drake,
Senior Pastor, Jubilee Community Church, Desoto, Texas
Thomas C. Gibbons, Senior Pastor
St. Barnabas Presbyterian Church, Richardson, Texas
gni"NAiF M.,.,.n
Pay Day&Title Lending
Commonly Asked Questions
Question 1: How do we know that the residents of the city of Grapevine are being affected by these
businesses?
There is a total of four Pay Day and Auto Title loan locations in the city of Grapevine. Last year,GRACE
conducted a random survey for one month. Each individual/family who requested assistance from
GRACE was asked whether they had ever applied for one of these loans. Of the people asked,over 20%
had applied for and received a Pay Day loan. Of those individuals, 60%said the conditions of the loan
affected their ability to pay for their basic needs including rent, utilities and food. In addition,all of
them had rolled over the loan at least 2 times.
Question 2: If these are lending institutions,why are they not required to follow best practices and
regulations set by Texas legislation?
Pay Day and Auto Title lenders operate as"credit access businesses"(CAB)in the state of Texas. This
has been sighted as a loophole that protects them from being required to adhere to best practices that
limit loan services. Basically they act as a loan "broker"and secure short-term loans through third-party
lenders. "The lender charges an interest rate near 10%,the state constitutional usury cap,and the CAB
charges unlimited fees to arrange service,and provide a letter of credit or guaranty to the third-party
lender who funds the payday and auto title loans."1
Question 3: If these institutions did not exist,where would these families be able to turn for
assistance?
Pay Day and Auto Title"lenders" present themselves as a viable service to families in need. The
proposed ordinance does not try to"close down"these institutions but simply regulate their practices
and minimize the unethical practices that trap families and individuals in worse financial crisis than what
brought them to these businesses in the first place. Many of the"lending"practices are not understood
by the people applying for the "loans"and therefore are a surprise to them once they are realized.
Question 4: Why wouldn't a city simply place a cap on the interest rate and fees that can be charged
by these businesses?
Only the State of Texas and the National Government have the power to dictate caps on fees/interest
rates. Right now,there is not great movement from the State of Texas to cap these fees so the
ordinances that have been passed by 40 Texas cities focus on areas that the city governments can
regulate like "limiting the number of installments or rollovers, requiring payments to reduce the loan
principal,and limiting loan amounts based on borrower income."2
Question 5: How many cities have passed similar ordinances?
Currently,40 cities in the state of Texas have passed ordinances that regulate some of the lending
practices of the CABs. To date, more than 9 million people live in a city that has passed basic consumer
protection restrictions through similar ordinances...that is close to 1/3 of all people living in the state of
Texas.
Question 6: Will the courts uphold these ordinances if one of these business files a law suit against
them?
Several of these businesses have filed lawsuits against the ordinances placing regulations on them. They
have all been supported in court including one that went through appeal to the Texas Supreme Court.
The Texas Supreme Court refused to hear the case. (The city of Austin passed a different ordinance that
tried to place other regulations that were deemed outside their legal jurisdiction. This one is NOT the
same ordinance that was passed by other cities.)
Question 7: Why do we not hear more about the negative effects associated with these loans?
Pay Day and Auto Title businesses use guilt and shame to keep their"clients"from being upfront about
the fact that they have received these loans. They ask questions like,"Why would you apply for a loan
you could not repay?"or"Why did you not understand the conditions of receiving the money?". GRACE
sometimes works with a family extensively before they admit that they have been trapped by the
ongoing charges associated with this type of loan. We believe that even the 20%who admitted in our
survey that they had taken out one of these loans is probably lower than the actual percentage because
of the shame that our clients feel for getting involved in such a risky financial endeavor.
1 See: https://www.texasappleseed.org/sites/default/files/Payday-Auto-Title-Lending-Tx MktOv-
Trends2012-2015Rev.pdf
2 See: https://www.texasappleseed.org/sites/default/files/Toolkit forCities SupplementalResources.pdf
Texas Cities That Have Adopted the Unified Ordinance
Updated May 2017
Dallas 2011
Austin 2011
San Antonio 2012
Universal City 2013
El Paso 2013
Houston 2013
South Houston 2013
Flower Mound 2013
Somerset 2013
Denton 2013 •
Balcones Heights 2013
Bellaire 2014
Bryan 2014
College Station 2014
West University 2014
Garland 2014
Baytown 2014
Midland 2014
Amarillo 2014
Brownsville 2014
Willis 2014
Socorro 2014
Pharr 2014
Seguin 2014
Galveston 2015
Corpus Christi 2015
Arlington 2015
Temple 2015
Mesquite 2015
Waco 2016
Killeen 2016
Longview 2016
Harker Heights 2016
Euless 2016
Hurst 2016
Bedford 2016
San Angelo 2016
Cedar Hill 2016
Canyon 2017
DeSoto 2017
https://www.texasappleseed.org/texas-cities-have-adopted-unified-ordinance
How Payday Loans Work
Payday and car title loans are small loans with very high fees and interest, typically 300%
annual percentage rate, though they average close to 500% APR in some states. Most of these
loans are short-term and due in full on a borrower's next payday, though some are structured as
longer-term loans payable in installments. The exorbitant fees charged by lenders make it
almost impossible for financially vulnerable borrowers to pay off their loans.
Before making a loan, legitimate lenders assess the ability of potential borrowers to repay it.
Payday lenders do not. In fact, their business is built on making loans borrowers cannot afford to
pay off, so that they will keep coming back and paying repeated fees on the same small amount
of money borrowed. Studies from groups like the Center for Responsible Lending and Pew
Charitable Trusts show that three quarters of payday lending volume is generated by "churned
loans." The very short-term due date frequently forces borrowers to take out their next loan
before payday. Here is how it works:
1. A typical borrower is a working parent who struggles to consistently pay the bills on time.
2. To obtain a payday loan, the borrower gives a payday lender a postdated personal check
or an authorization for automatic withdrawal from the borrower's bank account. In return,
she receives cash, minus the lender's fees. For example, with a $350 payday loan, a
borrower pays an average fee of about $60 in fees and so gets about$290 in cash.
3. The lender holds the check or electronic debit authorization for a week or two, usually
until the borrower's next payday.
4. At that time the loan is due in full, but most borrowers cannot afford to pay the loan back
and still make it to the next payday. Payday lenders have used aggressive collection
practices, sometimes threatening criminal charges for writing a bad check even when
state law prohibits making such a threat. Under these pressures, most payday
borrowers get caught in the debt trap. To avoid default, they pay another $60 to keep
the same loan outstanding, or they pay the full $350 back, but immediately take out
another payday loan, with another$60 fee.
In either case, the borrower is paying $60 every two weeks to float a $290 advance —while
never paying down the original amount of the principal. The borrower is stuck in a debt trap—
paying new fees every two weeks just to keep an existing loan (or multiple loans) outstanding.
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FAITH IN TEXAS
ORDINANCE NO.
AN ORDINANCE OF THE CITY OF SETTING FORTH
REGISTRATION REQUIRMENTS AND CREDIT EXTENSION GUIDELINES
FOR CREDIT ACCESS BUSINESSES AND PROVIDING A PENALTY.
WHEREAS, certain credit access businesses engage in abusive and predatory lending
practices,offering easy money to those members of our community who are in a tight spot
with onerous terms and fees;and
WHEREAS, the practices of certain access businesses cause members of our community
to become trapped in a cycle of short term, high interest loans resulting in large debt and
huge payments;and
WHEREAS, the Pew Charitable Trusts, in their publication entitled Payday Lending in
America: Who Borrows, Where they Borrow, and Why, (July 2012), wrote that "payday
loans are sold as two-week credit products that provide fast cash,but borrowers are actually
indebted for an average of five months per year."The report further noted that"on average,
a borrower takes out eight loans of$375 each per year and spends $520 on interest;"and
WHEREAS, the Pew Charitable Trusts, in their publication entitled Payday Lending in
America: Who Borrows, Where they Borrow, and Why, (July 2012), also noted: "How
much borrowers spend on loans depends heavily on the fees permitted by their state. The
same $500 storefront loan would generally cost about $55 in Florida, $75 in Nebraska,
$87.50 in Alabama, and $100 in Texas, even if it were provided by the same national
company in all those states. Previous research has found that lenders tend to charge the
maximum permitted in a state;"and
WHEREAS, the Pew Charitable Trusts, in their publication entitled Payday Lending in
America: Who Borrows, Where they Borrow, and Why, (July 2012), also stated that "the
vast majority of borrowers use the loans on a long-term basis, not temporary one. Thus it
seems that the payday loan industry is selling a product few people use as designed and
that imposes debt that is consistently more costly and longer lasting than advertised;"and
WHEREAS, the Community Financial Services Association of America (CFSA), the
national trade association for companies that offer small dollar, short-term loans or payday
advances includes the following in the "Member Best Practices" as listed on its interne
site (http://cfsaa.com/cfsa-member-best-practices.aspx): "Members shall not allow
customers to rollover a payday advance (the extension of an outstanding advance by
payment of only a fee) unless expressly authorized by state law, but in such cases where
authorized will limit rollovers to four or the state limit, whichever is less." The need for
consumer understanding was also outlined on this website: "A contract between a member
and the customer must fully outline the terms of the payday advance transaction. Members
(5) DEFERRED PRESENTMENT TRANSACTION has the meaning given that term
in Section 393.601 of the Texas Finance Code.
(6) DIRECTOR means the director of the department designated by the City Council,
City Manager, or City Councilor City Manager's Designee, to enforce and
administer this chapter.
(7) EXTENSION OF CONSUMER CREDIT has the meaning given that term in
Section 393.001 of the Texas Finance Code.
(8) MOTOR VEHICLE TITLE LOAN has the meaning given that term in Section
393.601 of the Texas Finance Code.
(9) PERSON means any individual,corporation,organization,partnership,association,
financial institution,or any other legal entity.
(10)REGISTRANT means a person issued a certificate of registration for a credit access
business under this chapter and includes all owners and operators of the credit access
business identified in the registration application filed under this chapter.
(11) STATE LICENSE means a license to operate a credit access business issued by
the Texas Consumer Credit Commissioner under Chapter 393, Subchapter G of the
Texas Finance Code.
.030-Violations; Penalty
(a)A person who violates a provision of this chapter,or who fails to perform an act required
of the person by this chapter,commits an offense.A person commits a separate offense for
each and every violation relating to an extension of consumer credit, and for each day
during which a violation is committed,permitted,or continued.
(b) An offense under this chapter is punishable by a fine of not more than$500.
(c) A culpable mental state is not required for the commission of an offense under this
article and need not be proved.
(d) The penalties provided for in Subsection(b) are in addition to any other remedies that
the city may have under city ordinances and state law.
.040-Defenses
It is a defense to prosecution under this article that at the time of the alleged offense the
person was not required to be licensed by the state as a credit access business under Chapter
393, Subchapter G, of the Texas Finance Code.
(a) A certificate of registration expires on the earliest of:
(1) One year after the date of issuance;or
(2)The date of revocation, suspension,surrender, expiration without renewal,or other
termination of the registrant's state license.
(b) A certificate of registration may be renewed by making application in accordance with
Section_.060. A registrant shall apply for renewal at least 30 days before the expiration
of the registration.
.090-Non-transferability.
A certificate of registration for a credit access business is not transferable.
.100-Maintenance of Records.
(a) A credit access business shall maintain a complete set of records of all extensions of
consumer credit arranged or obtained by the credit access business, which must include the
following information:
(1)The name and address of the consumer.
(2)The principal amount of cash actually advanced.
(3)The length of the extension of consumer credit, including the number of installments
and renewals.
(4)The fees charged by the credit access business to arrange or obtain an extension of
consumer credit; and
(5)The documentation used to establish a consumer's income under Section .110 of
this ordinance.
(b) A credit access business shall maintain a copy of each written agreement between the
credit access business and a consumer evidencing an extension of a consumer credit
(including,but not limited to,any refinancing or renewal granted to the consumer).
(c)A credit access business shall maintain copies of all quarterly reports filed with the Texas
Consumer Credit Commissioner under Section 393.627 of the Texas Finance Code.
(d)The records required to be maintained by a credit access business under this section must
be retained for at least three years and made available for inspection by the city upon request
during the usual and customary business hours of the credit access business.
(c) For every consumer who cannot read, every disclosure and notice required by law must
be read to the consumers in its entirety in the consumer's language of preference,prior to the
consumer's signature.
.130-Referral to Consumer Credit Counseling.
A credit access business shall provide a form, to be prescribed by the Director, to each
consumer seeking assistance in obtaining an extension of consumer credit which references
non-profit agencies that provide financial education and training programs and agencies with
cash assistance programs. The form will also contain information regarding extensions of
consumer credit, and must include the information required by .100(a)(1)-(5) of this
ordinance specific to the loan agreement with the consumer. If the Director has prescribed a
form in the consumer's language of preference,the form must be provided in the consumer's
language of preference.
Section 2. Should any article, section, part, paragraph, sentence, phrase, clause, or word of
this ordinance,for any reason be held illegal, inoperative,or invalid,or if any exception to or
limitation upon any general provision herein contained be held to be unconstitutional or
invalid or ineffective,the remainder shall, nevertheless, stand effective and valid as if it had
been enacted and ordained without the portion held to be illegal,inoperative,unconstitutional,
invalid,or ineffective.
Section 3.This ordinance shall take effect ,2013
ADOPTED THIS day of 2013.
CITY OF
ATTEST:
Mayor
City Clerk
APPROVED AS TO FORM:
City Attorney