How payday loans differ in other countries: UK vs. U.S

Payday loans are the most popular short term loans globally. The loans are available in all major economies globally. If you care to know how payday loans vary from one country to another (particularly the UK and U.S.,) look no further. Here’s what you need to know;

Payday loans in the UK

Although payday loans originated in the U.S., they have grown more rapidly in the UK. According to a recent PWC study, over 40% of all youth in the UK use payday loans. The UK payday loan industry is estimated to be worth billions of pounds today.

Typical UK payday loans range up to £500. Many UK payday loan lenders, however, offer flexible lending limits amounting to more than £1,000. Interest rates stand at approximately 25% per month for typical payday loans. There are however many lenders charging way less.

Largest Participants 

Wonga is the largest UK payday loan lender with approximately 30% market share. The second largest lender is Dollar Financial Group which owns the Money Shop as well as payday lenders; Payday UK, Ladder Loans, and Payday Express.

Regulation

The UK payday loan industry is regulated by the FCA (Financial Conduct Authority). The FCA took over the regulatory role from the FSA back in 2014 in an effort to exert tighter control on rogue payday loan lenders.
In January 2015, the FCA introduced strict regulations that guide the payday loan industry to date. For instance, payday loan lenders in the UK should not charge more than 0.8% interest per day. The total charges on all payday loans including interest and default charges are also capped at 100% of the total amount borrowed.

Status

The UK payday loans industry is currently transforming. The industry has had a bad name for years due to an increasing number of rogue lenders using unfair lending practices. The tightening regulation has however brought back sanity to the industry. The FCA has fined numerous payday loan lenders found guilty of using unfair lending practices. Although many lenders have closed shop, there is still a high demand for payday loans in the UK.

Payday loans in the U.S.

Payday loans originated from the U.S. They are also known as; cash advances, salary loans, payroll loans, cash advance loans, payday advance, etc. The loans date back to the 1900s where they were known as salary purchases. Initially, lenders would buy a borrower’s next salary for less and then disburse the difference to the borrower after deducting all applicable charges. Fast forward today, the industry has grown from 500 lenders to 22,000+ lenders. The U.S. payday loan industry is estimated to be worth over $46 billion today.

Regulation

Payday loan regulation in the U.S. varies widely from one state to another. To avoid unfair lending practices, many jurisdictions in the U.S. have APR (annual percentage rate) limits that all lenders must adhere to. It’s also worth noting that some jurisdictions in the U.S. have outlawed payday loans completely i.e. Georgia. In total, 14 states have forbidden payday lending. Other jurisdictions have few restrictions on lenders.

Some states also have laws limiting borrowers from taking payday loans repeatedly. Such states include Michigan, Illinois, Florida, Indiana and New Mexico just to mention a few. These states have statewide databases that require lenders to assess a customer’s eligibility to get a payday loan before issuing the loan. There is also regulation restricting the number of times a payday loan borrower can roll over their loan. Some states restrict rollovers i.e. Arizona. Other states i.e. Delaware allow a maximum of four rollovers.

Initially, payday loan rates were restricted in most U.S. states by the USLL (Uniform Small Loan Laws). The USLL restricted the rates at 36 to 40% APR.

Status

The U.S. payday loan industry caters for the young and poor mostly, low-income communities residing near military bases. A recent study conducted by Pew Charitable research also indicate that the payday loans in the U.S. are taken mostly for subsistence or recurrent spending as opposed to funding emergency cash needs. The interest rates charged on U.S. payday loans also remains higher than other alternative short term loans. The difference in regulation per jurisdiction is to blame for misinformation as well as ongoing unfair lending practices in the industry.

Is the Company Director of Swift Money Limited.
He oversees all day to day operations of the company and actively participates in providing information regarding the payday/short term loan industry.

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