APR caps continue to be a central feature of state regulation of non-bank loans. We routinely oppose rate cap legislation on the grounds that APR is not a sound measurement of the cost of the loan or consumer protection.
The following resources are intended to provide AFSA’s members with sources to inform and support industry advocacy against state APR caps and “all-in” / “military APR” caps.
Talking Points
- All-In APR
- APR Limits
- Consequences of the Over-Regulation of Installment Loans
- The Folly of APR Limits
- Should States Impose a 36% Rate Cap?
- Iowa – Rate Modernization
Fact Sheets & Issue Briefs
- All-In APR
- APR for 3-month loans of $300
- New Mexico Beware
- Rate Cap Effects on Other States
- Rule of 78s
- Simple Interest
50-State Surveys
- All-In Rate Caps
- APR Equivalents
- Rate Cap Legislation 2022
- Rate Cap Legislation 2021
- Small Loan Categories and Rates
- State Maximum Finance Charges
White Papers
Recent Advocacy
- AFSA Comment Letter to Governor: New Mexico HB 132 (March 3, 2022)
- Illinois Department of Financial & Professional Regulation Amended Rules (February 15, 2022)
- AFSA Comment Letter: New Mexico HB 132 – 36% All-In Rate Cap (January 26, 2022)
- Iowa HF 893 re: Military APR (May 11, 2021)
- Texas HB 2432 re: Small Loan Rates (April 13, 2021)
- Maine LD 522 re: Rate Caps (March 9, 2021)
- New Mexico HB 99 re: 36% Rate Cap (February 2, 2021)
- New Mexico SB 66 re: All-in Rate Cap (February 1, 2021)
- New Mexico HB 149 re: All-in Rate Cap (February 1, 2021)
- Illinois SB 1792 Veto Request re: Rate Caps (January 22, 2021)
Outside Resources
- Colorado Attorney General Consumer Lending Report
- Congressional Black Caucus Institute Annual Report
- Federal Reserve Board Research on Arkansas Rate Cap
- Consumers’ Research – The Unicorn Loan
- CSBS Survey – Consumer Finance Laws
- Illinois DFPR Installment Lending Trends Report
- Illinois Woodstock Institute Poll on Rate Caps
- NBCSL Resolution – Affordable Lending (2022)
- NBCSL Resolution – Affordable Lending (2015)
- NHCSL Resolution – Affordable Lending
- NOBEL Women Resolution – Affordable Lending
- Urban Institute – Prohibitions, Price Caps, and Disclosures: A Look at State Policies and Alternative Financial Product Use
Outside Studies
- Academic Study on Illinois Rate Caps (2023)
- A Larger and Longer Debt Trap? – NCLC (2018)
- A New Wave of Predatory Lending – NCLC (2015)
- A Survey of Payday Lending in Eugene and Springfield – US PIRG (2006)
- Auto Add-Ons Add Up – NCLC 2017
- Baggage of Consumer Installment Cash Lending – Mercatus (2016)
- Consumer Credit and the American Economy: An Overview – George Mason University (2014)
- Consumer Finance in NC – NCCOB (2011)
- Consumers Union Article – Consumer’s Union (2003)
- Credit Deserts – Mission Asset Fund (2012)
- Description: Core Lending Principles for Short-Term, Small-Dollar Installment Lending – OCC (2018)
- Does Finance Benefit Society? – Harvard University (2015)
- Effect of Payday Restrictions on Liquor Sales – Victoria University (2015)
- Financial Well-Being in America – CFPB (2017)
- Findings from the AFSA Member Survey of Installment Lending – George Mason University, AFSA (2014)
- FINTECH Lending: Financial Inclusion, Risk Pricing, And Alternative Information – Philadelphia Federal Reserve (2017)
- For Better or Worse? Effects of Access to High Cost Consumer Credit – Federal Reserve (2016)
- From Payday to Small Installment Loans – Pew Research (2016)
- How Does Legal Enforceability Affect Consumer Lending? – Stanford Law School (2017)
- How State Rates Affect Payday Loan Prices – Pew Research (2014)
- Marketing of Credit Add-On Products – CFPB (2016)
- Military Lending: Report to Congress – Department of Defense (2006)
- Millions use Bank Overdraft as Credit – Pew Research (2018)
- Payday Lending in America – Pew Research (2012)
- Payday Lending in America: Policy Solutions – Pew Research (2013)
- Payday Loans and Consequences – Federal Reserve, Vanderbilt, University of Pennsylvania (2013)
- Predatory Installment Lending in 2020 – NCLC (2018)
- Preserving and Expanding Consumer Access to Credit Products along the Nonbank-Supplied Small-Dollar Loan Landscape – Mercatus (2016)
- Remarks by Richard Cordray – CFPB (2010)
- Report on the Financial Well Being of US Households in 2019 (plus data to April 2020) – Federal Reserve (2020)
- Research on Financial Behaviors and use of Small Dollar Loans – Treasury, Urban Institute (2010)
- Self Evaluation Report – Texas OCC (2017)
- State Laws Put Installment Loan Borrowers at Risk – Pew Research (2018)
- Survey of Banked and Unbanked Households – FDIC (2015)
- The Power of the Salary Link: Assessing the Benefits of Employer-Sponsored FinTech Liquidity and Credit Solutions for Low-Wage Working Americans and their Employers – Harvard Kennedy School (2018)
- Underserved Market Study – CFSI (2017)
- Why 36%? – NCLC (2013)
- Consumer Borrowing after Payday Loan Bans – Federal Reserve, Cornell, Stanford (2016)
- Interest Rates: The Theory and Practice (Policy Paper) – World Bank (2018)
- Unequal Access to Credit – New York Federal Reserve (2019)
- Impacts of interest rate caps on the payday loan market: Evidence from Rhode Island – Texas A&M (2020)
- NY Fed Quarterly Report on Household Debt and Credit: Q4 2019 – New York Federal Reserve (2019)
- How do Small-Dollar, Non-Bank Loans Work? – Mercatus (2019)
- The Cost Structure of Consumer Finance Companies and Its Implications for Interest Rates – New York Federal Reserve (2020)
- FinTech Borrowers: Lax-Screening or Cream-Skimming? – Harvard (2018)
- Comment Letter on FINTECH Charter – CRL, NCLC et. al (2020)
- Survey of Consumer Expectations (SCE) Credit Access Survey – New York Federal Reserve (2020)