Posted on November 6, 2014

The CRA does not fit with the model of a bank that interacts with its customers in a branch-less mode. Here are a few examples of that poor fit.

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Posted on November 4, 2014

Regulators appear poised to finally accommodate the branchless distribution network of prepaid cards to the framework of the Community Reinvestment Act.

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Posted on October 30, 2014

Six ways that people will commit tax fraud in the coming year.

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Posted on October 24, 2014

I looked at the S-1 released by Citi in connection with their proposed initial public offering ("IPO") of shares in the OneMain Financial subsidiary. OneMain is a national consumer finance company with more than $8 billion in loans on its balance sheet. They also sell several types of add-on insurance products. Here are a few of the things that stood out to me.

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Posted on October 22, 2014

What I took away from World Acceptance's investor call this morning: a) they are going to try a new incentive system for branch managers which might help them to extract more cash from past due accounts, but which definitely allow them to make otherwise-charged-off loans appear to be active until the end of the 2015 tax season. b) they are building on a novel way of collecting on loans in Mexico c) they are not going to use risk-based pricing d) they think there might be something to this whole internet concept, after all.

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Posted on October 17, 2014

Rather than declare Corinthian Colleges, Inc. to be in default on their loan, Bank of America has formally announced that they will give the for-profit school more time to make up for their missed payments. Ironic, it seems, as a recent report says that some servicers of private student loans demand immediate and full repayment upon default of student loan debt.

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Posted on October 15, 2014

When CRA examiners hold banks accountable, they respond by making more mortgage loans to LMI borrowers. When the examiners let the banks off easy, banks tend to take their CRA obligations less seriously.

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Connecting the Dots: How Wall Street Brings Fringe Lending to Main Street

"I Feel Like I was Set Up to Fail: Inside a For-Profit College Nightmare."

This story was published in Salon Magazine on January 27th, 2014. In March, Senator Richard Durbin cited this story when speaking on behalf of his bill, The Student Loan Borrowers Bill of Rights.

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