What Is “Credit”? AfterPay, Earnin’, and ISAs

Adam Levitin |

there's good reason to think that some, if not all, ISAs involve a debt and are therefore "credit," for various federal regulatory purposes. The most natural read of the statutes is that ISAs are credit and subject to the full panoply of federal consumer finance regulations. Certainly from a purposivist...

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Student Loan Forgiveness Cannot Work Without a Right to a Payment History

Persis Yu |

The Trump Administration has raised the stakes for tens of millions of borrowers, pulling down planned consumer protections while advancing a sweeping new proposal that will cause more than 37 million borrowers’ loans to change companies in the coming years. The following guest post from Persis Yu, Director of the...

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Keeping America’s Promise

By Seth Frotman |

For years, advocates, law enforcement, and regulators have been sounding the alarm on the impending Public Service Loan Forgiveness crisis. Millions of dedicated public servants have devoted their careers to serving their communities, based on the promise of the PSLF program. But now, as the first cohort of eligible borrowers...

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It’s Time for More Cops on the Beat

By Seth Frotman |

For the past two years, this country has seen huge rollbacks of protections for consumers—from attacks on servicemembers’ rights to rules that protect borrowers of color from discrimination. Each time we think we’ve hit rock bottom and start believing that it can’t get any worse, the Trump Administration pulls out...

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What it means to be a student loan servicer: Guaranty Agency edition

Mike Pierce |

There has been a great deal of misinformation spread through state capitals about a special kind of private sector student loan company known as a "Guaranty Agency." Industry lobbyists have tried to convince lawmakers that these companies are not performing "student loan servicing" under the definition commonly included in state...

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The Predatory Underworld of Companies that Target Veterans for a Buck

Tariq Habash and Mike Saunders |

The recent law enforcement crackdown on for-profit colleges is well documented. These schools mislead students by promising a fast track to a brighter future and then loaded students up with mountains of debt for worthless degrees—a form of consumer fraud that stretches back for decades. But the public may be...

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