Payday Lending: An Ethics Evaluation

October 17, 2018

By: Daniel Stanley

Payday lending is a much-maligned industry, for good reason. The problems with payday lending run deeper than the actions of any individual lender. The insidious truth about payday lending is the business model is inherently unethical. Lenders must keep borrowers in debt to stay in business. If borrowers repay their loans quickly, lenders cannot profit.

This paper shows that the current structure of payday lending sets borrowers up to lose. John Rawls’ concept of justice as fairness is the framework for this analysis. Payday lending fails to uphold the standard of justice as fairness because the practice disrespects the fundamental requirements of fair cooperation.

WHAT ARE PAYDAY LOANS?

Payday loans are small-dollar, short-term loans borrowers repay with their next paycheck[1]. These loans typically range from $50-$1000[2], with an average size of $375[3]. Payday loans carry very high annual interest rates, commonly 400% or more[4]. However, payday loans are not meant to be year-long commitments. They are supposed to be quick infusions of cash that allow borrowers to resolve temporary financial shortfalls. If the loans are repaid quickly, the amount of interest paid remains low: about $15 for every $100 borrowed. Most payday loans have a two-week lifespan[5].

Payday loans are controversial because many people view them as debt-traps. Borrowers who do not meet payments must take out new loans to repay the old ones, triggering a vicious cycle. Critics accuse lenders of using misinformation and high fees to exploit the desperation of borrowers, many of whom are already poor, to make a profit.

Industry advocates respond that payday lending provides a beneficial and necessary service for people who are in difficult financial situations and for whom traditional sources of credit are not available. Proponents argue, if payday lending were made unavailable to consumers, the most vulnerable would suffer.

HOW DO PAYDAY LOANS WORK?

The mechanism of payday lending is simple. A borrower goes to a payday lender—either in a storefront or online—and requests a loan. To get this loan, the borrower must provide the lender three things: an ID, proof of employment, and access to their checking account. Most lenders require the borrower to either write a check, post-dated for the borrower’s next payday, or to provide the lender with electronic access to their checking account[6]. On the borrower’s payday, the lender cashes the check or accesses the checking account, and receives the amount of the loan, plus interest.

Lenders do not require any information beyond ID, proof of employment, and method of payment[7]. They do not conduct a credit check or otherwise check the borrower’s ability to pay back the loan[8][9]. Thus, people with poor credit history or severe financial problems can be approved for payday loans.

WHY GET A PAYDAY LOAN?

Payday loans are marketed as quick solutions to temporary financial shortfalls[10]. An unexpected bill—car repair, medical bill, traffic ticket—can easily exhaust someone’s savings. Payday loan borrowers typically have cash flow difficulties—lack of savings or a credit cardor poor credit history, for example —and thus are left with few options when a financial disaster strikes[11]. Payday loans, advocates argue, enable cash-deprived people to deal with an emergency immediately, and repay the loan with their next paycheck.

But payday loans, despite being marketed as emergency measures, are commonly used to pay for non-emergency expenses. A 2012 Pew Charitable Trusts report found that 69% of borrowers used their payday loans for recurring expenses, such as utility bills, credit card bills, rent and mortgage payments, and food. Only 16% used loans for unexpected, emergency expenses[12].

Despite controversies over their uses and misuses, payday loans are a very popular method of borrowing. Payday lenders serve almost a sixth of all American families[13]. The prevalence of payday lending is due, in part, to the combination of a lack of savings in American families and a high rate of underbanking. In 2015, 46% of adults reported they could not cover a $400 emergency expense with savings[14]. Underbanking is when a person uses entities outside the traditional banking system, such as payday loans, for her financial services. 19.9% of American households, over 50 million adults, were underbanked in 2015[15]. The widespread vulnerability of American household finances, coupled with a lack of access to traditional banking services, push people into the payday lending industry.

ETHICAL FRAMEWORK: JUSTICE AS FAIRNESS

Since fairness is the central issue concerning payday lending, John Rawls’ concept of justice as fairness is appropriate to evaluate the ethical issues surrounding payday lending.

Critics claim lenders violate fairness. Borrowers, due to their lack of alternatives, are not negotiating under fair terms. Borrowers, due to exploitative loan structures, are not given a fair chance to repay their loans.

Industry defenses also center around fairness. Given the high rate of delinquency inherent to payday lending, the small value of each loan, and the short term of each loan, seemingly high interest rates are fair. In fact, it would be unfair for stricter regulations to deprive borrowers of payday lending, an overwhelmingly popular resource millions of Americans take advantage of.

John Rawls posits human beings are both rational and reasonable; this allows them to act fairly with each other. People are rational in their ability to identify and systematically pursue their self-interest. And people are reasonable when they acknowledge fairness, honoring reciprocal terms of cooperation even at the cost of their own interest. A reasonable person accepts restrictions on her behavior, so long as everyone else is bound by the same restrictions[16].

So, while it can be rational for someone to take advantage of a superior bargaining position to profit, such behavior would not be reasonable if that person does not accept such behavior if she were the one at a disadvantage[17].

If lenders behave reasonably, treating borrowers as they themselves would want to be treated, then they behave fairly. If, however, lenders use their rationality to exploit borrowers, they behave unreasonably, unfairly, and unethically[18]*.

ETHICAL PROBLEMS WITH PAYDAY LENDING

Payday Lending: An Ethical Evaluation — …ending exploitation could end the payday loan industry and a business that can only profit through exploitation should not exist.

Criticisms of payday lending center around one idea: lenders exploit borrowers for profit. The problem with this argument is that payday lending is not very profitable. Multiple studies find payday lenders operate on a less than 10% profit margin[19]. There are more payday lending operations in America than there are Starbucks, but Starbucks is more profitable. Lenders are not making huge profits off the backs of poor people.

This is not to say that lenders do not exploit borrowers. Payday borrowers are very vulnerable to exploitation. Payday loans are marketed for a very specific person: someone with an urgent need for cash and a lack of other credit options. Desperate need, combined with lack of alternatives, creates a situation ripe for exploitation.

Critics of payday lending call the industry a debt-trap. Borrowers in desperate situations accept loans with exorbitant interest rates and short lifespans. When they inevitably fail to repay these loans, they must re-borrow to pay back the original loans. Taking out a new loan to repay an old one is called “rollover”, and critics say it is essential to the payday lending business model[20].

Rollover is very common in the payday lending industry, leading many people to call payday lending predatory lending. Lenders do not attempt to reduce rollover because repeat business is where their profit comes from. Lenders cannot lose under this system, but borrowers can and do. If the borrower repays the loan, the lender gets her money back, plus interest. If the borrower rolls the loan over, the meter keeps running and the lender profits even more. It’s like Vegas: the players can take a hand or two, but the house will always win. And the real money is with the repeat customers.

Industry advocates claim interest rates reflect the operational costs of lenders. They say, in the current climate of economic instability, with so many people living paycheck to paycheck, people need quick access to emergency credit. Denying access to payday loans might increase bankruptcy or cause people to seek out unregulated or illegal lenders[21]. The industry’s rapid growth and immense size indicate there is a pressing need for its product.

If it is true that lenders exploit borrowers by creating a debt-trap, then exploitation seems to be a necessary part of the business model. Lenders currently do not make huge profits. If they cannot make a lot of money when they exploit people, they probably cannot make any money at all when they do not exploit people. And a business that cannot profit cannot exist. Yet, ending exploitation could end the payday loan industry and a business that can only profit through exploitation should not exist.

To determine whether the payday lending industry could function as an ethical business, we should begin by examining the most severe ethical issues that exist in the status quo. These are:

Frequent rollover
Misleading advertising
Failure to assess a borrower’s ability to repay
Abusive collection strategies
Short-term lending periods

NOTE:

When not otherwise specified, we will assume that borrowers obtain payday loans to address anomalous financial events. Payday loans are not marketed as long-term, repeat credit; they are for unusual events.
We will suppose payday lending’s purpose is to transition borrowers who are in temporary crisis situations from financial insecurity and financial security. If payday lenders do not give borrowers a realistic chance at regaining stable finances, their profiting on the financial collapses of their clients is unethical.
Regulation of payday loans varies by state. This paper will discuss payday loans in a general sense. Some of the unethical behaviors will be regulated by law in some states, but not others.

Frequent Rollover

Payday loans are tailored for the exiles of the traditional banking system, the unsound credit. And they are responses to financial anomalies that put unusual stress on borrower finances. Under these circumstances, some payday loans will inevitably end in rollover. But rollover should not be so common.

The numbers are staggering: only 36% of new payday loans are repaid in one term[22]. From the Consumer Financial Protection Bureau, the federal agency that regulates payday lending:

“More than four out of five payday loans are re-borrowed within a month, usually right when the loan is due or shortly thereafter. And nearly one-in-four initial payday loans are re-borrowed nine times or more, with the borrower paying far more in fees than they received in credit.”[23]

The widespread inability of borrowers to repay their debts indicates the structure of payday loans does not give borrowers a fair chance to repay them.

Lenders benefit when borrowers fail to repay their loans quickly. Borrowers who roll their loans over pay additional rollover fees, in addition to the interest on their loans, before acquiring a new loan for the amount of the original principle[24]. Because payday loans have very high interest rates, commonly 400% or more, such loans can become very expensive very quickly, even without factoring in rollover fees.

Not everything that is disadvantageous to the borrower is unethical. And rollover itself is not a disaster. If you take a $200 loan for a car repair, roll it over twice, and end up paying a little over $300, it’s still far preferable to losing your car, not being able to get to work, and losing your job. Or missing a rent or electricity payment and losing your home or power. Rollover is not necessarily a disaster for the borrower; even with multiple rollovers, the loan can still be a net positive.

The ethical problem arises when the payday lending model relies upon high rates of rollover to be profitable. Lenders therefore have an incentive to keep borrowers in debt.

A working research paper from the Federal Reserve Bank of Kansas City found: “The profitability of payday lenders depends on repeat borrowing”[25]. When states enact laws which limit the number of rolloverslenderscan offerborrowers, payday lending storefronts close[26]. This is because a significant portion of lender revenue comes from repetitive lending: sometimes as much as 70%[27].

When payday lenders require high rates of rollover to stay in business, their interests become opposed to those of the borrowers. The borrowers want to pay off their loans quickly and return to financial security. The lenders want borrowers to stay in debt, paying interest and rollover fees.The conflicting interests of borrowers and lenders result in lender behaviors that put borrowers at drastic disadvantages in paying back their loans. Some of the worst practices are described below.

Misleading Advertising

Lenders have historically failed to inform borrowers of important facts about their loans. In any contract, it is important for all parties to have a thorough understanding of their obligations. It is paramount that borrowers, who already face financial distress, understand the terms of the loans and the likely effects those terms will have on their financial situations.

Payday loan advertising is notoriously unscrupulous. Payday loan ads were so blatantly manipulative that both Google and Facebook banned them[28]. Replete with phrases like ‘quick cash’ and ‘no credit check’, payday loan ads traditionally downplay the long-term effects of loans, the risk of rollover, and the extent of fees[29].

Misleading advertising leads to misuse of loans. Payday loans are supposed to be short-term, emergency-response loans. Yet the average borrower spends five months out of the year in debt[30]and 69% of borrowers use their loans for recurring expenses[31]. The payday lending industry acknowledges payday loans are inherently unsuitable for long-term borrowing[32]. 400% and higher interest rates make these loans terrible long-term credit strategies. Lenders must ensure borrowers know payday lending is unsuitable for recurring expenses.

Rawls’ justice as fairness intends to respect both the rationality and reasonability of people. A lender’s failure to adequately educate borrowers, or to intentionally mislead them, is unreasonable; such behavior prevents borrowers from exercising their rationality.

Reasonable people honor principles of fairness, even at the expense of their own self-interest. They recognize that they must behave in the way they would expect others to behave. People who exploit others by means of a superior bargaining position act rationally, but not reasonably; such people would not condone such exploitation if it was applied to themselves.Reasonable people behave in accordance with the principles they acknowledge as fair and universal terms of cooperation[33]. No one acknowledges ignorance and exploitation as fair; no one would voluntarily allow themselves to be deceived.

The most reasonable thing lenders can do is accurately inform borrowers about their loans. When borrowers are informed and financially literate, they can use their rational faculties to assess the loans’ effects upon their finances. Lenders can, in this way, respect the rationality of their borrowers. Such behavior is reasonable; everyone wants to maximize their self-interest, and everyone wants their goals to be respected by others.

Of course, not all borrowers will be rational enough to anticipate the effects of payday loans upon their finances. People make mistakes; this is why the lenders, who are more familiar with the common effects of payday loans, must educate themselves about borrowers’ financial situations and help them through the loan process. Such help is not a gratuity; the point of payday lending is to help borrowers through difficult financial times. Unfortunately, lenders almost universally fail to provide the assistance they should. This leads to the next issue: failure to assess a borrower’s ability to repay her loans.

Failure to Assess Borrower Ability to Pay

With rollover so common, a lender’s failure to check for a borrower’s ability to repay a loan is irresponsible and unfair.

One of the reasons rollover is so common is lenders typically fail to thoroughly underwrite, or check for a borrower’s ability to repay the loan prior to issuing it. Lenders only ask borrowers for three things before issuing a loan: ID, proof of employment, and access to a checking account. There is no industry-wide standard that mandates thorough underwriting.

Because lingering payday loans are so detrimental to borrowers—interest can exceed the principal within a few months[34]—lenders put borrowers at risk when they neglect to underwrite their loans. A 2012 Pew Charitable Trusts report found that “on average, a borrower takes out eight loans of $375 each per year and spends $520 on interest”[35].

Rawls’ system of justice as fairness seeks to enable people to pursue their ends within a fair system of cooperation. To this end, Rawls believes that society should attempt to promote equality of opportunity by correcting for, among other things, “how [citizens] are affected by illness and accident” over the course of their lives[36].

Payday lending claims to provide people with protection against unexpected events like illness and accident by smoothing cash flow difficulties during emergencies. Payday loans can do that, in some circumstances[37]. But high-interest lending can harm as easily as help. When debt fails to disappear, and people begin to prioritize payday loan payments over everyday necessities[38], the medicine becomes its own disease.

Given that payday lenders claim to offer an emergency-response service, they have a duty to analyze how their loans will affect borrowers. Lenders, who know that rollover is common and expensive, cannot expose their clients to the dangers of default without a reasonable expectation that borrowers will be able to repay their loans. Caveat emptor is a dereliction of duty. Lenders cannot claim to provide relief when they do nothing to ensure the responsible use of their product, which has the potential to do so much harm.

Abusive Collection Strategies

Debt collection is a part loansof every type. But payday lenders commonly employ collection strategies unethically disadvantageous to borrowers. Such collection strategies contradict the very purpose of payday lending, which is to help borrowers resolve temporary financial problems.

The most common unethical collection strategies are:

Taking first-pass at a borrower’s paycheck, ahead of other bills

Mandating lump-sum repayment

First-Pass

Payday loan payments take priority over all other bills. When a borrower obtains a payday loan, she gives the lender a post-dated check (or access privileges to a checking account). Upon a borrower’s payday, the lender cashes the check (or electronically withdraws the funds).

By taking the money directly out of the borrower’s account on payday, lenders ensure they get paid before anyone else. Borrowers are forced to payfor their payday loans before rent, utilities, credit cards, and food. A 2012 study found in households with under $50,000 annual income, access to payday loansmade food stamp usage 20% more likely and child support payments 10% less likely[39].

By prioritizing payday loan payments over all other obligations, even daily necessities, payday lenders once again make their product resemble the problem it is supposed to solve. Lender first-pass prerogative risks triggering the kinds of financial emergencies payday loans are supposed to alleviate.

Collecting payment in this way can prevent borrowers from paying other bills or affording necessities, can overdraw from the borrower’s account (triggering overdraft fees), and even risks closing the borrower’s bank account.

Giving lenders first-pass at borrower paychecks undermines the claim that payday lending is about crisis-management. It is transparently unreasonable to expect borrowers to put payday loans above absolute necessitieslike food andchild support. Lenders should respect borrowers’ holistic financial situations; when medical bills, utilities, and child support payments do not have the power to immediately and forcibly carve themselves out of someone’s paycheck, neither should payday loans. Giving lenders first-pass is an unethicalprioritization of responsibilities.

Lump-sum Repayment

A typical feature of payday loans is lump-sum repayment, or balloon repayment: the borrower must repay the loan in a single installment[40]. Lump-sum repayment is a burdensome requirement on such short-term loans, particularly for borrowers whose finances are already strained.

Consider the situation of the archetypal payday borrower: this person has two weeks to pay for a financial anomaly, while meeting normal responsibilities, and repay a payday loan.

If payday loans are truly crisis-management tools, lump-sum repayment is counterproductive to that goal. As indicated by the rolloverrate, financial crises are rarely two-week long affairs. Financial security is rarely one paycheck away.

Lump-sum repayment is one of the reasons first-pass is so onerous. Paying for an entire loan while still meeting regular responsibilities is beyond the power of a single paycheck. And lenders know this; for many, lump-sum repayment is impossible.

Some states have already instituted laws requiring lenders to offer payment plans as alternatives to lump-sum loans, even mandating that borrowers should have the option to convert their loans into payment plans. However, many lenders have made such plans more expensive in the short-term, disincentivizing the option[41].

For many people facing a crisis, financial security is a far-off goal. A slow march to security is often the only path forward. Payday loans should respect the gradual nature of this processand refrain from punishing borrowers from taking their time.

Short-Term Lending Periods

Naturally, moving payday lending away from a lump-sum model would extend the lifetime of loans, allowing borrowers to repay their loans with installments over time. This would end the payday loan as a short-term loan.

But in practice, these loans are not short-term at all. When the average borrower spends five months in debt[42], when little more than a third of new loans are resolved in a single term[43], payday loans are short-term in name only.

The staggering rate of rollover shows that most financial emergencies cannot be resolved in two weeks. In recognition of this, the payday loan industry should adapt to the reality that financial stability is not achieved quickly. Short-term lending sets up borrowers to fail.

CAN PAYDAY LENDING BE ETHICAL?

The above practices make rollover the likely outcome of a large percentage of paydayloans. Unfortunately, this result is no accident. Payday lenders, who do not have large profit margins, receive a large portion of their revenue from rollover. To stay in business, lenders need a significant number of their clients to fail to repay their loans. This goal is unethical for three reasons:

It creates incentive to break the loan agreement

When lenders need rollover to profit, they need borrowers to fail to repay their loans. This means that lenders need borrowers to break the loan agreement. A contract designed to be broken is inherently unethical. When lenders issue contracts they know borrowers will be unable to honor, they are not behaving reasonably; they would not be willing to make contracts they knew they could not honor. A basic requirement of a contract is that there be a reasonable expectation that both parties will meet their obligations.

Lender dependence on rollover creates antagonism between lender and borrower

When lenders require high rollover rates to profit, it perverts the lending process. Lenders and borrowers are supposed to be in common cause: the lender gives money, while the borrower uses that money and pays it back with interest. Both sides benefit. It is a cooperative, symbiotic relationship.

But when lenders need borrowers to rollover, this relationship collapses. When there is not enough money for both lenders and borrowers to profit, they cease cooperating and start competing. Lenders set up borrowers to fail, transforming the symbiotic relationship into a parasitic, even predatory, one.

The system puts disproportionate burden on the least advantaged borrowers

Rollover is the option of people who cannot repay their loans. It triggers new fees and keeps the borrower paying interest. When lenders profit off rollover, they profit off their least-advantaged clients.

According to Rawls’ justice as fairness, society operates on two principles of justice:

Everyone must have the same basic liberties (e.g. freedom of speech, association)
Social and economic inequalities must:
1. Be the result of fair equality of opportunity and
2. Be of the greatest benefit to the least-advantaged members of society[44]

Profiting on rollover reverses the principle; it takes money disproportionately from the least advantaged borrowers, while giving them no new or special benefits. A system designed to take the most from those who have the least offends basic moral intuitions and refined justice frameworks alike.

While Rawls’ two principles of justice are not meant to apply to individual institutions, but rather the basic structure of society, it is apparent the welfare of the least advantaged deserves special attention. If a society wants to achieve equality of opportunity, it must ensure adequate protection for the most vulnerable citizens: protection against unforeseeable disaster, and protection from exploitation when such disaster strikes.

CONCLUSION

Politicians and pundits, secular and religious leaders alike, have criticized the payday lending industry as an exploitative debt-trap. The bad odor the industry has acquired is not due to the actions of a few bad apples, but from an inherent corruption in its basic structure. Reforming the industryto ethical standardswould eliminate this moral flaw.

When a single unexpected expense can exhaust a household’s savings, there must be an avenue of relief. Unfortunately, payday lending, although claiming to provide such relief, has no interest in promoting financial security. The business model only works when borrowers remain mired in debt.

The current payday lending model is a toxic mixture of high operational costs and low returns. But it is possible integrating payday lending into large institutions could reform payday lending into an ethical business. Entities such as large national banks or government institutions could use their existing infrastructure and technology to offer small-dollar loans.

Policy proposals already recommend moving payday lending to national banks or government institutions like the post office[45]. Big banks have the technology to underwrite loans cheaply and effectively. The government has an interest in the financial security of its citizens, so they can contribute to the economy and not have to seek welfare or similar relief. Relocating payday lending under the umbrella of a new actor could transform payday loans into a legitimate chance at financial security.

If payday loans disappear, the problems that lead people tothem will not. We must ensure that if we deprive people of this alternative, they have another that offers them a fair chance for financial security.

[1]https://www.occ.gov/news-issuances/advisory-letters/2000/advisory-letter-2000-10.pdf

[2]https://www.credit.com/loans/loan-articles/the-truth-about-payday-loans/

[3]http://www.pewtrusts.org/-/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingexecsummarypdf.pdf

[4]https://www.fdic.gov/news/news/financial/2005/fil1405a.html#foot2, https://www.credit.com/loans/loan-articles/the-truth-about-payday-loans/

[5]https://www.credit.com/loans/loan-articles/the-truth-about-payday-loans/

[6]http://www.pewtrusts.org/en/research-and-analysis/fact-sheets/2016/01/payday-loan-facts-and-the-cfpbs-impact

[7]https://www.cfsaa.com/facts

[8]https://paydayloaninfo.org/facts

[9]https://www.fdic.gov/news/news/financial/2005/fil1405a.html#foot2

[10]http://www.pewtrusts.org/-/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingexecsummarypdf.pdf

[11]https://www.fdic.gov/news/news/financial/2005/fil1405a.html#foot2, https://www.federalreserve.gov/econresdata/feds/2016/files/2016056pap.pdf https://www.federalreserve.gov/econresdata/feds/2016/files/2016056pap.pdf

[12]http://www.pewtrusts.org/-/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingreportpdf.pdf

[13]https://www.theatlantic.com/magazine/archive/2016/05/payday-lending/476403/

[14]https://www.federalreserve.gov/2015-report-economic-well-being-us-households-201605.pdf

[15]https://www.fdic.gov/householdsurvey/2015/2015execsumm.pdf

[16]Rawls, John. Justice as Fairness: A Restatement.Harvard University Press. Cambridge, MA. 2001. p. 6-7

[17]Rawls, John. Justice as Fairness: A Restatement. Harvard University Press. Cambridge, MA. 2001. p. 7

*Rawls’ framework is an appropriate tool for an analysis of payday lending because:

Industry critiques and defenses have accepted fairness as a desirable value
Payday lenders market their product as a response to misfortune, whichis a contingent inequality Rawls specifies society must address to ensure equality of opportunity
Legislation against predatory lending already exists and expresses fairness as a value that society can and should defend

[19]https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?referer=https://en.wikipedia.org/&httpsredir=1&article=1227&context=jcfl, https://www.adamsmith.org/blog/if-payday-loans-were-ripping-people-off-then-thered-be-a-better-profit-margin-than-this, https://www.theatlantic.com/magazine/archive/2016/05/payday-lending/476403/

[20]http://www.responsiblelending.org/state-of-lending/reports/10-Payday-Loans.pdf

[21]https://www.cfsaa.com/facts

[22]https://www.federalreserve.gov/econresdata/feds/2016/files/2016056pap.pdf

[23]https://www.consumerfinance.gov/about-us/newsroom/cfpb-finalizes-rule-stop-payday-debt-traps/

[24]https://www.reuters.com/article/us-usa-consumer-paydayloans/new-u-s-rule-on-payday-loans-to-hurt-industry-boost-banks-agency-idUSKBN1CA24K, https://www.consumerfinance.gov/ask-cfpb/what-does-it-mean-to-renew-or-roll-over-a-payday-loan-en-1573/, https://www.opploans.com/content/articles/2016-state-payday-loan-regulation-guide/

[25]https://www.kansascityfed.org/~/media/files/publicat/reswkpap/pdf/rwp09-07.pdf

[26]http://www.pewtrusts.org/-/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingreportpdf.pdf?la=en&hash=87E01A73BA3DFC090D9D3034862FD76B14E2C15D

[27]http://www.pewtrusts.org/-/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingreportpdf.pdf, https://www.huffingtonpost.com/entry/payday-loan-industry_us_5637671ce4b0c66bae5ce89a

[28]https://www.washingtonpost.com/news/the-switch/wp/2016/05/11/google-to-ban-payday-loan-advertisements/?utm_term=.5af0090aa561, https://www.facebook.com/policies/ads/

[29]https://www.theguardian.com/money/2014/may/16/fca-loan-credit-companies-break-advertising-rules , https://www.occ.treas.gov/topics/consumer-protection/payday-lending/index-payday-lending.html

[30]http://www.pewtrusts.org/en/research-and-analysis/reports/2012/07/19/who-borrows-where-they-borrow-and-why