The Agencies note that because clients making use of DAP frequently have cashflow problems or blemished credit records, such loans provide a heightened credit risk to lending banks
The combination of a high-cost product and short repayment period creates a risk of some customers becoming trapped in a cycle of high-cost borrowing over an extended period of time in the Agencies’ view. 5 This period, described as “churning” of loans, is characterized by the Agencies as “just like” the practice of “loan-flipping,” that they have actually formerly recognized as a feature of predatory financing. 6 The Agencies suggest that the style among these services and products frequently leads to such consumer behavior and it is “detrimental to” the client. Although alleged “cooling off” durations, that is, minimal times imposed between deposit improvements, have already been instituted by some banking institutions, the Agencies find the present types of such plans become “easily prevented” and “ineffective” in preventing consistent usage. (mais…)