Sam has a side business repairing fences and one of his bids was just approved to begin work immediately. Now he needs to come up with the money to buy supplies a few weeks before he receives payment from the customer. Because of unpaid medical bills from several years ago, he has a low credit rating, and applications for small business loans have been denied.
Joan is an artist with a promising jewelry line. She’s invited to sell her products at a popular bridal show that will result in big sales and future business opportunities at local boutiques. However, Joan must come up with money upfront to pay for booth space, displays, and material to make the jewelry. Since Joan has high credit card debt, she can’t access traditional financing.
The FDIC says nearly a quarter of U.S. households used alternative financial services in the past 12 months. One major factor is that two out of five Americans experience income swings of more than 30 percent month to month. In fact, 15 percent of U.S. consumers — approximately 37 million adults— do not have a bank account, according to a 2016 Pew Charitable Trust Study.
These statistics underscore the need for alternative financial services to assist unbanked, underbanked, and sub-prime consumers who have credit scores under 600.
It’s clear that consumers need to be fully educated on responsible borrowing, managing finances, and budgeting. There’s a reason why the CFPB established new regulations on certain lenders, including payday loans, auto title loans, deposit advance products, and longer term loans with balloon payments.
In general, regulations seek to provide consumer protection and ensure that lenders are acting in an ethical and professional manner. The concern is regulation that impacts and limits consumers’ access to credit. In an ideal market, regulated lenders provide financial services that meet a market need. As lenders compete for business (providing credit), it becomes the consumer’s responsibility to review the options and make the best choices for themselves.
An open market will foster competition and ensure that the appropriate lenders survive. Competition fosters innovation and drives new choices for consumers without the need for externally imposed limits.
Consumers Need Access to Emergency Cash
A major consideration that can’t be overlooked is that certain customers with poor credit scores many times need access to emergency cash. If their credit scores are too low, they are not able to borrow from banks or may not be able to obtain help from friends and family.
By definition, a subprime consumer (550-620 FICO) is likely to default on a loan 50 percent of the time. That’s a costly business decision for any lender.
If the market steps in and imposes more regulations on alternative financial service providers, the likely result is that loan requirements will become more conservative. Banks and traditional financing options will remain unavailable for borrowers with the lowest credit scores, and the increased cost of doing business could push some small-dollar alternative lenders out of the market.
Now, before you jump for joy and say that this is exactly what needs to happen, consider the potential consequences.
With many Americans living paycheck to paycheck, getting laid off, medical bills, an unexpected car repair, or emergency trip to a sick relative may require quick cash. Where will the consumers with low credit ratings turn in difficult circumstances and emergency situations?
One possibility, in the absence of small-dollar lenders, is that borrowers will get loans from less desirable lenders that operate under the radar, off the grid. Consumers who are desperate to pay bills, rent and car repairs, or buy medicine and other necessities of life may turn to loan sharks and other nefarious entities.
Does this seem like an unlikely scenario? Probably not.
Another possibility is that these consumers who tried to take care of themselves by borrowing emergency cash simply give up. With fewer options to fix their temporary liquidity problems, the need for government assistance will rise. If these consumers can’t pay for car repairs, can’t get to work, and lose their jobs, the result may be increased unemployment claims. Even more troublesome, the snowball effect could increase welfare programs and housing subsidies.
The reality is that underbanked consumers and borrowers with imperfect credit need alternative financial services. There are responsible alternative financial services and lenders who can provide small-scale, short-term funding.
If underbanked consumers and borrowers with poor credit ratings aren’t permitted to access credit, social welfare programs will be required to offset the consumers’ inability to meet short-term cash needs. This catastrophic situation will increase the cost and number of citizens on social assistance. Ultimately, all taxpayers will be burdened with increases in social welfare.
The question is rather than over-regulating this sector of the credit market, doesn’t a free market on certain alternative financing options seem to be a better alternative?
Guy Dilger is vice president of marketing at Plain Green, LLC. With more than 12 years of experience designing groundbreaking marketing strategies for Fortune 500 companies and financial technology brands, Dilger is known for generating engaging content and compelling concepts that resonate with targeted consumers. Prior to Plain Green, Dilger held senior positions within fintech and retail spaces where he managed national marketing campaigns and customer-centric loyalty initiatives for Sears and Kmart. Previously, he was part of the management team at Limited Brands where his marketing work in support of Express brand included CRM, email, web-based programs and the redesign and relaunch of a private label credit card. Dilger has an MBA, as well as a bachelor of science in economics, from Southern Methodist University.