Charles M. Horn
“While the principal customer base of the payday lending industry is lower-income and lower-middle-income consumers, as a general matter these consumers must have at least a steady job, a bank account and a social security number in order to qualify for a payday loan.”
In an essay entitled Regulation and Self-Policing will Influence Consumers’ Access to Payday Loans, Washington D.C. lawyer Charles M. Horn challenges the notion that payday loan consumers are the poorest, low-income people…
Horn also stated that the advice given by consumer advocate organizations (to seek traditional bank products) is naive:
“…the fact that consumers who use the services of payday lenders often have limited, if any, access to mainstream financial services, and hence it is more than passing naive for consumer organizations to suggest that these consumers ought to look to credit cards and other traditional bank products (which, if they are available at all, may end up being more costly than the payday lending alternative).”
Charles M. Horn is a partner in the Washington, D.C. office of law firm Mayer, Brown, Rowe & Maw. Prior to joining the firm, he held senior positions in the Securities and Exchange Commission and the U.S. Department of Treasury’s Office of the Comptroller of the Currency.
Sources:
Regulation and Self-Policing will Influence Consumers’ Access to Payday Loans by Charles M. Horn (Washington Legal Foundation)
In Defense of Moderation: Avoiding Overegulation of Special Purpose Entities by Charles M. Horn (Washington Legal Foundation)
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