Payday Loans versus Pawn Shops: The Effects of Loan Fee Limits on Household Use Robert B. Avery Federal Reserve Board Katherine A. Samolyk Consumer Financial Protection Bureau Sept 23, 2011 The views expressed are those of the authors and do not necessarily represent those of the Board of Governors of the Federal Reserve System or the Consumer Financial Protection Bureau. 1 This Paper Uses data from the January 2009 Unbanked/Underbanked Supplement to the Current Population Survey Examines how state-regulated fee ceilings on payday loans and pawn shops affect households’ use of these products Explores conjectures about market dynamics (Flannery and Samolyk, 2007) Store operations involve largely fixed costs in supplying the product Stores generally charge the fee ceiling rate If demand is relatively price inelastic (“good” a necessity, few substitutes) Level of fee ceilings determines profitable scale of store operations and number of stores needed to meet inelastic loan demand: Quantity of loans supplied need not change 2 Findings Demand appears to be relatively price inelastic; funds primarily used to meet basic living expenses and lost income Payday loan use adjusted for demographic characteristics does not vary systemically with fee ceilings in the range where stores currently operate (except for the very lowest ceilings) Pawn shop use is higher where fee ceilings are higher Controlling for use associated with household demographics, stores per capita vary positively with fee ceilings Within a range; lower ceilings may not markedly reduce payday loan availability 3 Payday Loans Fairly standardized: 2 week loans of several hundred dollars, typically 15-20$ fee per $100 borrowed Minimal underwriting Borrower gives lender a post-dated check for amount borrowed and fee ID, recent checking account statement, and a pay stub, check of recent payment history (Teletrak) On maturity date, borrower pays loan or lender deposits check; or borrower pays another fee and lender extends another loan to the borrower 4 Pawn Shop Loans Pawnshops loans are collateralized by the items being pawned; LTVs in the 40-60% range. Borrower need not have a bank account, a regular source of income, or a credit check. Trade groups estimate that the typical pawn loan is for about $80, with a contract maturity of 30 days and loan fee of 20 percent of the loan amount. If borrower does not repay or renew; the lender takes physical possession of the item 5 State Payday Regulations States regulate payday lending Effective APRs generally exceed state usury ceilings (>390% APRs) States generally have had to pass “enabling legislation” permitting the payday product; regulations can include Fee ceilings Loan amount limits Limits on rollovers or consecutive loans Usury ceilings or very low payday loan fee limits effectively “prohibit” payday lending in 13 states and DC 6 State Pawn Shop Regulations Pawn shops also regulated by states; regulations can include: Fee limits The amount of time before a loan is considered in default Return requirements (that sale proceeds in excess of the loan amount and fees must be returned to the borrower) Pawn shops operate in all states; even those with very low limits 7 Evidence about Customer Use Evidence of frequent payday loan use: Caskey (2005): state government data show most customer use payday loans more than 6 times a year; one quarter had 14 or more loans during the year. Flannery and Samolyk (2007): store data from two large payday lenders: 40 percent of loans were roll-overs/renewals; roughly one half of loans were to accounts that had taken out more than six loans that year Skiba and Tobacman (2008) data for a large payday lender indicate half of the borrowers default on a loan within a year of their first loan; but have paid fees for five payday loans before they defaulted (90% of original loan’s principal). Evidence that payday borrowers are likely to be financially constrained (although working, moderate income and educational attainment) Ellihasuen and Laurence (2001) credit card balances near limits; outstanding balances Logan and Weller (2009) lower wealth, more likely to have been denied credit 8 Evidence about Customer Use Less known about pawn shop use: According to Pawnshopstoday.com, “Around 80 percent of pawn loans tend to be repaid and that repeat customers account for much of the loan volume; often borrowing against the same item repeatedly.” 9 Evidence About Supply Side Focal Point Pricing (DeYoung and Phillips): Charge payday ceiling rate and compete away excess profits by entry Flannery and Samolyk (2007) Stores tended to charge ceiling rates Scale economies imply that profits related to loan volume: more loans, bigger loans Prager (2009) Higher fee limits associated with more payday stores per capita 10 Evidence About Supply Side Higher fee limits associated with more payday stores per capita (Caskey(1991), Prager (2009), Shackmen and Tenney (2006)) Some evidence that pawn shops make larger loans when ceilings are lower (Shackmen and Tenney, 2006) 11 How do fee ceilings effect availability of payday and pawn shop loans? Within current range of ceilings where lenders can operate Conjecture one Higher fee ceilings should reduce demand But if there is excess demand at the ceiling rate; supply determines equilibrium quantity Higher fee ceilings increase the quantity sold Conjecture two Higher fee ceilings reduce volume of loans needed to cover fix costs and be profitable Increases the number of stores a market can support Relatively little affect on quantity sold 12 Our Strategy The 2009 Unbanked/Underbanked Survey: A supplement to the Jan 2009 CPS sponsored by the FDIC. Large nationally representative sample allows state-level estimates of usage. Included questions about : Use of payday loans and pawnshop loans Reasons for using a product rather than going to a bank Reasons why the credit was needed Matched with the rich CPS demographic data 13 Our Strategy We use CPS data to estimate loan demand associated with household demographic characteristics using only withinmarket variation. Use these estimates to construct geographic estimates of usage adjusted for the demographic component of demand. Examine how adjusted-usage estimates are related to state fee ceilings 14 Payday Loan and Pawnshop Demographic Demand 60 percent of borrower say they could not borrow elsewhere. Major use of funds: basic living expenses; lost income and specific bill or expense also important reasons Multivariate results: Demographics of Use Higher payday or pawnshop use: renter; has children Unemployed; moderate age (25-45); divorced, separated or widowed; Lower use of both product: college degree; foreign born Higher payday use: disabled; moderate income; moderate education; single female head of household; Black; Native American; (Lower use among retired) Higher pawnshop use: unbanked; lower income; single; smaller renter effect; larger Native American effect; smaller Black effect; larger UE effect; less of an education effect; no FHOH effect; 15 Table 5: Multivariate Analysis of Household Demographics and AFS Credit Use Independent Variable A: Use payday loan 1 Coefficient Std. Error B: Used Pawnshop 2 Coefficient Std. Error 0.0049 0.0469 *** 0.0034 <.0001 0.0486 0.0030 *** <.0001 0.0091 *** 0.0021 <.0001 0.0586 0.0040 *** <.0001 0.0084 0.0028 *** Native American Parentage (no chlidren) 0.0253 0.0104 0.0262 0.0073 *** Children 18+ 0.0204 0.0052 *** <.0001 0.0173 *** 0.0036 <.0001 Children <18 0.0320 0.0055 *** <.0001 0.0174 *** 0.0039 <.0001 0.0192 0.0050 *** 0.0434 *** 0.0035 <.0001 -0.0105 0.0045 * -0.0041 0.0031 0.0140 0.0055 * -0.0013 0.0039 HH income$15-30K 0.0102 0.0044 * -0.0122 *** 0.0031 <.0001 HH income 30-50 0.0138 0.0045 ** -0.0175 *** 0.0031 <.0001 HH income $50-75K 0.0027 0.0049 -0.0263 *** 0.0034 <.0001 -0.0075 0.0050 -0.0289 *** 0.0035 <.0001 Unbanked Renter Race (NHW) Black -0.0051 * Labor Force Status (employed) Unemployed Retired Disabled Household Income (LT$15K) HH income>$75K Householder Age (LT 25) Age 25-34 Age 35-44 0.0260 0.0056 *** <.0001 0.0107 0.0040 ** *** 0.0113 0.0041 ** * 0.0227 0.0058 <.0001 Widowed 0.0132 0.0063 * 0.0097 0.0044 Divorced/separated 0.0199 0.0053 *** 0.0165 *** 0.0037 <.0001 Single 0.0039 0.0054 0.0085 0.0038 0.0070 0.0040 Marital Status (married) * Education (no HS diploma) High school diploma Some college/AA 0.0151 -0.0014 0.0028 0.0042 *** -0.0022 0.0029 -0.0109 0.0035 College degree -0.0117 0.0049 * Post graduate -0.0116 0.0049 * -0.0051 0.0034 0.0057 *** -0.0044 0.0040 *** -0.0161 0.0030 Female head of household 16 Foreign-born 0.0213 -0.0273 0.0043 <.0001 ** *** <.0001 How Fee Limits Affect Use State Fee Limits per $100 State Group Not Permitted Payday Fee Range NA Pawn Fee Range Low $10-$12 $1-$9 Medium $15-$16 $10-$19 High $17-$20 $20-$25 No Ceiling/Very High > $20 or None 17 None Second Stage: Fee Ceilings and Loan Use Net of Demographics Dependent variables: Usage adjusted for demographics (actual usage less usage predicted by demographics) in a given geographic area (Equivalent to “fixed effects” from 1st stage) Sample includes 365 geographic areas identified in the CPS data in states where payday stores can operate Explanatory variables include: Fee ceiling categories Categorical variables for broad region; rural dummy; median income of market where the area is located Relative fee ceilings on “substitute” product 18 Table 6: Multivariate Analysis of Fee Ceilings and Adjusted AFS Credit Usage A: Incidence of Payday borrowing adjusted Coefficient Intercept Payday fee ceiling group 3 Std. Error 0.0050 Group 1 (lowest ceilings) -0.0271 Group 3 -0.0103 Group 4 0.0054 Group 5 (no ceilings) -0.0063 Pawn shop see ceiling group 4 Group 2 (next to lowest ceilings) 0.0067 0.0060 *** 0.0046 * 0.0084 0.0071 Group 3 Group 4 (no ceilings) Relative pawn shop fee ceiling Lower Higher Region: North -0.0013 Region: West 0.0112 Rural Market income group 2 Market income group 3 Market income group 4 (highest) Dependent Variable Mean Number of geographic areas r squared 2 -0.0010 0.0003 -0.0003 -0.0125 0.0055 0.0047 * 0.0055 0.0061 0.0068 0.0076 1 Coefficient Std. Error 0.0042 -0.0286 -0.0094 0.0051 -0.0065 0.0069 B: Incidence of Pawnshop borrowing adjusted 1 Coefficient Std. Error CoefficientStd. Error -0.0171 0.0128 -0.0061 0.0042 -0.0092 0.0050 -0.0034 0.0039 0.0238 0.0137 0.0127 0.0138 0.0129 0.0048 0.0032 0.0042 0.0074 -0.0006 0.0043 0.0032 -0.0099 0.0035 ** 0.0068 0.0025 ** -0.0063 -0.0008 -0.0031 -0.0047 0.0030 0.0033 0.0037 0.0040 * 0.0066 *** 0.0047 * 0.0084 0.0071 -0.0041 -0.0073 0.0043 0.0083 0.0222 0.0018 0.0121 0.0067 0.0002 0.0058 -0.0129 0.0041 ** * 0.0135 0.0052 0.0069 0.0028 -0.0001 0.0016 0.0015 -0.0106 0.0057 0.0063 0.0070 0.0078 -0.0047 -0.0005 -0.0027 -0.0030 0.0035 0.0038 0.0044 0.0050 0 0 365 0.0765 365 0.0799 0 365 0.1416 *** 0 516 0.1310 Nonlinear effect of payday fee ceilings on usage adjusted for local demographics; lower in the lowest payday fee-ceiling group—but also lower in the high fee-ceiling group ($17-20 per $100) Pawn shop use is highest in the high fee-ceiling group ($20-25 per $80) 19 Effects of Fee Ceiling on Specific Demographic Groups Table 9: Pawnshop Residuals by State Fee Ceilings <$10 Group Variables Total Households $10-$19 Group $20-$25 Group No Ceiling Group -0.012 -0.001 0.004 -0.003 Black -0.025 0.003 0.002 -0.014 Hispanic -0.008 -0.005 0.010 -0.010 Asian -0.003 0.003 0.000 -0.002 Native American -0.048 -0.001 0.020 -0.017 Other race -0.011 0.005 -0.008 -0.024 NonHispanic White -0.010 -0.002 0.003 -0.001 HH income<$15K -0.033 0.003 0.009 -0.015 HH income$15-30K -0.015 -0.002 0.003 0.005 HH income 30-50 -0.014 -0.005 0.008 -0.003 HH income $50-75K -0.005 -0.001 0.005 -0.005 HH income>$75K -0.004 0.000 0.001 -0.003 HH income missing -0.009 -0.005 -0.002 0.000 No high school diploma -0.021 0.002 0.005 -0.005 High school diploma -0.016 -0.002 0.004 -0.003 Some college/AA -0.012 -0.004 0.005 -0.003 College degree -0.005 -0.002 0.005 -0.001 Post graduate -0.004 0.002 -0.003 -0.005 -0.029 0.004 0.001 -0.016 Race Household Income Education 20 Female head of household Fee Ceilings and Stores per Capita Only have store count data at the state level Use estimates from demographic regressions to summarize mean use (demand) at the state level Find state fee ceilings (and demographics) are strong predictors of the number of payday stores and pawn shops per capita. 21 State fee ceilings (and demographics) are strong predictors of the number of payday and pawn stores. Table 7: Multivariate Analysis of AFS Credit Fee Ceilings and Stores per Capita Panel A: Number of payday stores per-capita Coefficient Std. Error Intercept -2.4352 0.6319 *** -0.4631 0.2071 * Payday fee ceiling group 2 Group 1 (lowest ceilings) Group 3 Group 4 0.3321 0.9400 Group 5 (no ceilings) 0.1527 * 0.3251 ** 0.5290 0.2779 Estimated demand from Demographics 74.0100 14.1603 Dependent Variable Mean n r squared 1.0331 37.0000 0.6599 *** Panel B: Number of pawnshop stores per-capita Payday States Coefficient Std. Error Coefficient Std. Error -0.7320 0.2794 * Group 2 (next to lowest ceilings) 0.2674 0.1202 * 0.2438 0.0822 ** Group 3 0.4473 0.1069 *** 0.4238 0.0769 *** 0.3429 0.1458 * 0.3425 0.0957 *** 40.2732 11.6707 43.1111 9.0218 *** Intercept Pawn shop see ceiling group Estimated demand from Demographics Dependent Variable Mean n (states) r squared 1 -0.7754 0.1957 *** 3 Group 4 (no ceilings) 22 All States ** 0.4373 0.3993 37 0.5516 51 0.6450 *, *, *** : Significant at the 5%, 1%, and .1% levels 1 First column regressions only use geographic areas in states where payday lending is permitted. The second uses all areas. 2 Base group is states with $15-$16 fee caps 3 Base group is states with the lowest fee caps Payday Loans and Pawn shop “Substitutability” Table 10: Interactions between Payday and Pawn Shop Fee Ceilings Average Incidence of product usage by group adjusted for demographics Payday loans Payday loan Fee Pawn Shop Loan Fee Ceiling Ceiling Lower Same Higher No Payday 1.20 1.14 $10-$12 1.62 3.37 2.40 $15-$16 5.22 4.59 $17-$20 4.31 4.66 4.39 High or No ceiling 4.15 5.90 Pawnshop Use Payday loan Fee Pawn Shop Loan Fee Ceiling Ceiling Lower Same Higher No Payday 1.11 1.92 $10-$12 0.85 3.65 2.18 $15-$16 1.65 1.89 $17-$20 1.97 2.48 2.39 High or No ceiling 1.86 1.77 23 Findings Demographics do explain a lot of the cross-market variation in usage. Adjusted Payday Use appears to be relatively uncorrelated with state fee ceilings Lower in the lowest fee ceiling group but also in the medium fee ceiling group ($17-20 per $100 borrowed); even though lower ceilings appear to reduce the number of stores Adjusted pawnshop is somewhat more sensitive to fee ceilings; highest use in higher fee group ($20-25 per $100 borrowed) and stores per capita are the highest for states in this fee group 24 Issues Use of small high cost loans: repeated use to make ends meet Other AFS products: Auto-title lending; refund Anticipation loans; RTO Direct deposit advance What is the best we can do? Product limitations Disclosure, framing the costs Enforcement Subsidize more affordable product 25