Varde - Standards of conduct for investment in payday and installment lenders AFR NCLC CRL PA 010417

A letter from consumer advocacy groups to Värde Partners arguing that payday and installment loans create debt traps and demanding the adoption of strict investment standards, including a 36% APR cap and ability-to-repay determinations.

• The authors argue that payday and car title lenders often charge annual interest rates of 300 percent or higher, creating a 'long-term debt trap' that leads to bankruptcy, delinquency, and difficulty paying essential bills like rent and mortgages.
• The document asserts that installment lenders may use fees, insurance, and ancillary payments to push actual loan rates into high double or triple digits, despite potentially lower stated interest rates.
• The authors propose five standards of conduct for investors in this sector: a maximum APR of 36% (or lower if state law dictates), a good faith determination of a borrower's ability to repay without re-borrowing, a ban on mandatory arbitration, a prohibition on schemes to circumvent state laws (such as 'rent-a-bank' or tribal partnerships), and a ban on lobbying to increase rates or fees.

APA

Private Equity Stakeholder Project (2018). Varde - Standards of conduct for investment in payday and installment lenders AFR NCLC CRL PA 010417. http://pestakeholder.org/wp-content/uploads/2018/01/Varde-Standards-of-conduct-for-investment-in-payday-and-installment-lenders-AFR-NCLC-CRL-PA-010418.pdf

Chicago

Private Equity Stakeholder Project. Varde - Standards of conduct for investment in payday and installment lenders AFR NCLC CRL PA 010417. 2018. http://pestakeholder.org/wp-content/uploads/2018/01/Varde-Standards-of-conduct-for-investment-in-payday-and-installment-lenders-AFR-NCLC-CRL-PA-010418.pdf.

Wikipedia

{{cite press release |author=Private Equity Stakeholder Project |title=Varde - Standards of conduct for investment in payday and installment lenders AFR NCLC CRL PA 010417 |date=4 January 2018 |url=http://pestakeholder.org/wp-content/uploads/2018/01/Varde-Standards-of-conduct-for-investment-in-payday-and-installment-lenders-AFR-NCLC-CRL-PA-010418.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{privateequitystakeholderproject2018varde, author = {{Private Equity Stakeholder Project}}, title = {{Varde - Standards of conduct for investment in payday and installment lenders AFR NCLC CRL PA 010417}}, publisher = {Private Equity Stakeholder Project}, year = {2018}, month = jan, url = {http://pestakeholder.org/wp-content/uploads/2018/01/Varde-Standards-of-conduct-for-investment-in-payday-and-installment-lenders-AFR-NCLC-CRL-PA-010418.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }