[AS_NEL]

Hey All,
I was wondering if any of you read this yet and I wanted to know your thought.
http://techcrunch.com/2015/08/06/fun...ill-of-rights/

[Chambo]

Here are the guiding principles of the Small Business Borrowers Bill of Rights:

The Right to Transparent Pricing and Terms, including a right to see an annualized interest rate and all fees
The Right to Non-Abusive Products, so that borrowers don’t get trapped in a vicious cycle of expensive re-borrowing
The Right to Responsible Underwriting, so that borrowers are not placed in loans they are unable to repay
The Right to Fair Treatment from Brokers, so that borrowers are not steered into the most expensive loans
The Right to Inclusive Credit Access, without discrimination
The Right to Fair Collection Practices, to prevent harassment and unfair treatment

But then this would make these fly by night shops actually responsible and accountable. the kids can play Tough Guy Loanshark then

[MCNetwork]

There's a lot of subjective jargon in there. How do you define terms like "fair", "responsible" and "non-abusive"?

[Chambo]

There's a lot of subjective jargon in there. How do you define terms like "fair", "responsible" and "non-abusive"?

that is determined by the judge and the jurisdiction. so what may fly in Texas won't in NY, FL, etc. In other words, it would give the merchants much more leverage in suing folks for shady practices.

[fundgorilla]

I just got the email on this subject, so I thought I'd come over here and take a look at the DF posts - and of course its here too. When I read that tech crunch article, I'm reminded of many successful press releases and advertisements from the past that have concealed their intentions with an 'its good for you' approach - in reality this kind of features and benefits approach to selling is strictly prewar.

"The coalition is encouraging all parties in the industry to sign on to follow these guiding principles." The implication is that if they don't they'll be shamed huffpo style. Translation: "Nice little shop you have there, shame if something happened to it, don't you think you should give us $500 to register for the "Small Business Loan Providers Association Seal of Approval" I mean, if we don't have you on our list, that's like having a negative D&B plus a full page on the ripoff report - and I know you know how expensive it is to clean those two items up."

Now, on the surface, yes, a lender's bill of rights does make sense, and as a preemptive strike against regulatory involvement in the industry….well….nice try.

I have no problem signing such a document - I'm already adhering to it frankly - but in return I want to file charges against every merchant that sends me a doctored file. That kind of stuff can cut both ways.

I do believe that compliance, or lack thereof, will ultimately divide our industry by those who do, and those who don't, with those who don't going out of business as swiftly as a Long Island Stock Brokerage below its margin requirement. That day is coming, and the smart man wonders what the bad players will move on to next. That, of course, won't be happening to me.

In general, when people come to me with high-minded language about their "Integrity, reputation, and strength", my response is the bronx cheer.

[Sean Cash]

"The coalition is encouraging all parties in the industry to sign on to follow these guiding principles." The implication is that if they don't they'll be shamed huffpo style. Translation: "Nice little shop you have there, shame if something happened to it, don't you think you should give us $500 to register for the "Small Business Loan Providers Association Seal of Approval" I mean, if we don't have you on our list, that's like having a negative D&B plus a full page on the ripoff report - and I know you know how expensive it is to clean those two items up."

This kind of leverage exists in the online consumer lending/payday space. If a member outside the organization is doing something illegal, the trade group will report the evildoer directly to the FBI and work with them to kill them off.

[fundgorilla]

This kind of leverage exists in the online consumer lending/payday space. If a member outside the organization is doing something illegal, the trade group will report the evildoer directly to the FBI and work with them to kill them off.

Well, swift-boating your competition is also an old-school tactic, and of course all's fair - those on the wrong side of the law should be prepared for the worst. I sleep much better at night knowing I'm completely bulletproof against such things. What bothers me is some phony outfit passing themselves off as a sanctimonious arbiter of all things right and proper, and I'm not surprised to see Tech Crunch (an AOL Huffpo subsidiary) leading the shaming charge as that's pretty much what that outfit does 24/7, but of course without any actual compliance related gains. The point is to scold, shame, and frighten people into compliance, and ultimately, to support some anti finance agenda. Everything is political these days, and this is too.

Of course, I'm eager to see the bad players move on to making license plates or cooking meth or whatever they do for money when the Belfort tactics no longer deliver. I grow weary of working to defeat the bad reputation the knuckle draggers have given our industry, but I don't do that with press releases and condescending language. I do that by living my compliance plan every day and setting a standard that's far stricter than others would apply to me.

[CLucas]

How many brokers out there have submitted an application; gathered all the required docs, only to get a decline, with information that was on the application itself. Meaning the additional documentation gathered from the (customer) was for nothing because the deal was already going to be declined with data the underwriter already had. Yet the (customer) gathered all doc's and is now "SCRATCHING" his head wondering, why the hell did they ask for all that info. Like it or not you just created a pissed off skeptic/critic of this industry. I hope part of transparency means Underwriting first, additional doc's to support underwriting's decision then contracts generated.

[FUNd]

How many brokers out there have submitted an application; gathered all the required docs, only to get a decline, with information that was on the application itself. Meaning the additional documentation gathered from the (customer) was for nothing because the deal was already going to be declined with data the underwriter already had. Yet the (customer) gathered all doc's and is now "SCRATCHING" his head wondering, why the hell did they ask for all that info. Like it or not you just created a pissed off skeptic/critic of this industry. I hope part of transparency means Underwriting first, additional doc's to support underwriting's decision then contracts generated.

How can you decline a file if you don't have all the supporting documentation to make a proper decision. Also, why so you piece mail your UW? You should have a complete file before the UW even has a look at it. Submitting incomplete files is a great way to get black balled and have your files end up at the bottom of the pile.

[CLucas]

Example: Credit Score does not require a Bank Statement. You can easily decline on a Credit Score.

[FUNd]

Example: Credit Score does not require a Bank Statement. You can easily decline on a Credit Score.

Not really. I've funded scores in the 400's with strong compensating factors.

[MCNetwork]

I've funded 9003 FICO's as well. Good cash flow and time in business trumps credit score.