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Federal Regulation of Consumer Credit: the Cause Or the Cure for Predatory Lending? Margot Saunders and Alys Cohen BABC 04-21 March 2004

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Federal Regulation of Consumer Credit: the Cause Or the Cure for Predatory Lending? Margot Saunders and Alys Cohen BABC 04-21 March 2004 Joint Center for Housing Studies Harvard University Federal Regulation of Consumer Credit: The Cause or the Cure for Predatory Lending? Margot Saunders and Alys Cohen BABC 04-21 March 2004 This paper was produced for Building Assets, Building Credit: A Symposium on Improving Financial Services in Low-Income Communities, held at Harvard University on November 18-19, 2003. Margot Saunders and Alys Cohen are both attorneys at the National Consumer Law Center. © by Margot Saunders and Alys Cohen. All rights reserved. Short sections of text, not to exceed two paragraphs, may be quoted without explicit permission provided that full credit, including © notice, is given to the source. Any opinions expressed are those of the authors and not those of the Joint Center for Housing Studies of Harvard University, or of any of the persons or organizations providing support to the Joint Center for Housing Studies. Summary of Paper Federal law has long been a primary source of important individual rights, from voting and other civil rights to workplace safety. State law, however, has traditionally provided most protections for consumers in the marketplace. Instead of leading the way on consumer protections, federal law – with the important exception of the Consumer Credit Protection Act1 – has unfortunately degraded the traditional protection of consumers through state law and has created and supported the advance of predatory lending in this nation. These changes can be laid on the doorstep of federal preemption of state consumer credit laws, the expansion of federal banking agency powers, and congressional changes to the tax code. Since the 1980's, these developments on the federal level have been sending two erroneous messages: 1) that deregulation of consumer credit is the optimal policy; and 2) that sound personal financial planning requires the use of home equity to secure consumer credit. In fact, both of these messages are wrong, and have been a significant – if not the primary – cause for the escalation of the predatory lending problem which is steam rolling through communities across America. While abusive and fraudulent credit scams have always been a problem in a commercially oriented culture, the problems in the past 15 years caused by the explosion of predatory lending are new in the history of personal credit. Consumers are weighed down with too much debt, and the wrong kind of debt, in the forms of unsecured credit cards, high-cost auto loans, payday lending, rent-to-own transactions, and – the most expensive and damaging variation on dangerous credit – predatory mortgage lending. The continued escalation of bankruptcy filings,2 and the continued depletion of savings and increase in personal debt are indicative of a credit system gone awry. 1 The Federal Consumer Protection Act include inter alia: 1) The Truth in Lending Act, 15 U.S.C. § 1601, et seq., simply mandating a uniform method of disclosing the costs and terms of consumer credit transactions, passed in 1968. 2) The Equal Credit Opportunity Act, 15 U.S.C. § 1691, et seq., prohibiting discrimination in the granting of credit, passed in 1974. 3) The Electronic Fund Transfer Act, 15 U.S.C. § 1693, et seq., providing a structure for electronic transfers of consumer funds, and providing some consumer protections against loss, passed in 1978. 4) The Fair Debt Collection Practices Act, 15 U.S.C. § 1692, establishing consumer protections against over- aggressive debt collectors, passed in 1978. 5) The Fair Credit Reporting Act, 15 U.S.C. § 1681, establishing some standards protecting consumers in the gathering, compiling and delivery of personal information, the first version of which was passed in 1979. 6) The Home Ownership and Equity Protection Act, 15 U.S.C. § 1602(aa) and § 1639, providing some special protections for consumers in high cost mortgages, passed in 1994. 2 For example, in 2002, a record was set with more than 1.5 million bankruptcy filings during the 12-month period ending June 30th, including $1.47 million personal bankruptcies. Reuters, U.S. Sees Record Number of 1 Credit is no longer considered an important but dangerous tool to be applied carefully to appropriate situations, but is now akin to a necessity. Deregulation has been pursued in order to protect the perceived need for unrestricted credit access, no matter how great the cost. As a result, the rate of increase in foreclosures continues to rise annually, the depletion of home equity continues and the American dream of homeownership – and all of the security, family and community stability that flows from it – is lost forever for millions of American families. States Have Traditionally Provided Consumer Protections The states have always been the main source of consumer protections, as well as a laboratory for devising new approaches to such laws.3 Except for a limited number of important, but non-traditional, consumer protections mostly passed in the 1970s and ‘80s by the U.S. Congress, the states have traditionally provided all of the safeguards for consumer credit. It has been recognized for centuries that borrowers and lenders often do not enter credit contracts on equal footing. The absence of equal bargaining power may manifest itself in different ways. Most obviously, a debtor who, for example, has lost his job and has defaulted on his mortgage may agree to almost any terms to obtain new credit and to avoid losing his home. Usury statutes have traditionally been justified as attempts to prevent the exploitation of such a needy borrower by limiting the price that she may be asked to pay for the loan.4 Yet, modern credit laws often address more subtle effects of unequal borrowing power as well as flagrant Bankruptcies, Aug. 14, 2002. Unfortunately, even this record does not begin to tell the full story. Household debt is at a record high relative to disposable income. American Bankruptcy Institute, http://www.abiworld.org/stats/newstatsfront.html. Moreover, many families are too poor to declare bankruptcy because they are flat broke. 3 Other than the Federal Consumer Credit Protection Act, only the following federal laws were passed to provide consumers protection: 1) The FTC Act, 15 U.S.C. § 45(n), prohibiting unfair or deceptive practices, but with no private enforcement, passed in 1938 2) The Magnuson Moss Warranty Act, 15 U.S.C. § 2301 et seq., providing federal protections for consumers in certain warranty situations, passed in 1975. 3) The Real Estate Settlement Procedures Act, 12 U.S.C. § 2601 et seq., providing for disclosures and some substantive protections for consumers in home mortgages, passed in 1974. 4See, e.g.,Ghirardo v.Antonioli, 883 P.2d 960 (Cal.1994)(purpose of usury law is ‘‘‘to protect the necessitous, impecunious borrower who is unable to acquire credit from the usual sources and is forced by his economic circumstances to resort to excessively costly funds to meet his financial needs.’’’); Jersey Palm-Gross, Inc. v. Paper, 658 So.2d 531, 534 (Fla.1995)(purpose of usury laws is to ‘‘protect borrowers from paying unfair and excessive interest to overreaching creditors ’’; and ‘‘to bind the power of creditors over necessitous debtors and prevent them from extorting harsh and undue terms in the making of loans’’); Trapp v. Hancuh, 530 N.W.2d 879 (Minn.Ct.App.1995)(purpose of usury laws is ‘‘to protect the weak and necessitous from being taken advantage of 2 exploitation. It is a fact of the modern consumer credit market that creditors, not borrowers, draft loan documents, and that the terms of credit contracts offered to consumers are basically non- negotiable. A potential borrower can ‘‘take it or leave it” and go elsewhere, though sometimes the ‘‘elsewhere’’ is not so easy to find. Moreover, the increased complexity of credit makes it difficult for consumers to do any meaningful comparison shopping to determine whether it is best to ‘‘leave it” or not. The ubiquity of adhesive credit contracts, combined with the ignorance of almost all consumers about the fine print contained in these contracts, leads to opportunities for the exploitation of borrowers that are just as great as those presented by the classic desperate borrower. Purpose of Usury Laws and Their Progeny The lending of money or commodities such as grain in return for interest has been documented as early as 3000 B.C. and, undoubtedly, predates that. From its inception, the practice seems to have caused controversy in many societies. In part, the charging of interest was condemned on moral and religious grounds; it was considered ungodly and uncharitable for one person to profit from the need of another. Yet there were also many concrete grounds for opposing money lending. In hard times, a borrower could lose all his property and be sold into slavery to pay his debts. The evils caused by usury were very real, and moneylending was at times banned outright. In England, it was not until 1545 that Parliament legalized charging interest in the modern sense.5 English usury statutes, particularly the Statute of Anne, were adopted by the American colonies prior to independence. Variations on these statutes remain in effect to this day in many states, and are commonly referred to as ‘‘general ’’usury laws because they purport to set a ceiling for all loans of money or forbearance of debt in a jurisdiction, not just for particular types of lenders or credit transactions. With very few exceptions, general usury laws were the only statutes regulating credit costs in the United States prior to the twentieth century. Until the latter part of the twentieth century all states had general usury laws prohibiting the lending of money at interest rates greater than a certain number. This changed as the structure by lender who can unilaterally establish the terms of the loan transaction ’’; distinguishing position of corporations, presumed to be in an equal bargaining position).
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