early draft of my new financial stability paper May 26, 2016Posted by Bradley in : financial regulation , add a comment
summer writing May 16, 2016Posted by Bradley in : financial regulation , add a comment
Over the summer I am working on a new paper on financial stability, which is a development of a paper I wrote for a book edited by Pablo Iglesias-Rodriguez, Anna Triandafyllidou & Ruby Gropas with the title The Financial Crisis and Paradigm Shift: Legal, Economic and Political Perspectives forthcoming July 2016. My chapter is Changing Perceptions of Systemic Risk in Financial Regulation. The new paper is looking at climate change and Brexit as issues of financial stability and I am taking it to Law and Society at the beginning of next month. Meanwhile I also have produced a draft of a paper on Financial Stability, Financial Services and the Single Market .
payday loans: csr and regulation May 13, 2016Posted by Bradley in : consumers , add a comment
Google’s new policy on payday loan ads which will be banned defines the relevant loans as follows:
We will no longer allow ads for loans where repayment is due within 60 days of the date of issue. In the U.S., we are also banning ads for loans with an APR of 36% or higher. When reviewing our policies, research has shown that these loans can result in unaffordable payment and high default rates for users so we will be updating our policies globally to reflect that.
The policy doesn’t just seem to apply to the worst sort of payday loans. The NY Department of Financial Services says that payday loans are typically repayable within 2 weeks and can carry an interest rate of 400%. The Google announcement doesn’t say how Google will think about issues such as roll-over of loans (where loans originally repayable within a two week period end up being outstanding for longer because they are rolled over into new loans) or high fees which might not be characterized as part of an APR. A study by the FCA in the UK published in 2014 found that payday lending consumers were frequently surprised by roll-over or extension of the loans and the fact that this would raise the cost of the loans.
What’s different now is that an increasingly small number of technology firms control what an ever expanding number of people see online. And they’re willing to go beyond what is circumscribed in law to make their own decisions – maybe shaping society in areas where governments won’t act.
This article, and the Google announcement, seem to suggest that what Google is doing here is engaging in corporate social responsibility (CSR). But in fact payday lending is an area where Governments are becoming more active: payday lending is already illegal in a number of states (such as New York, although the rules in different states do vary) and it has been targeted by the CFPB: just this week the CFPB announced that it had taken Action Against Check Cashing and Payday Lending Company for Tricking and Trapping Consumers and last month the CFPB published a report which shows that online payday lending customers are at risk of being subject to overdraft and non-sufficient funds charges imposed by their banks and even of having their checking accounts closed. New rules on payday lending are expected soon. And other jurisdictions, such as the UK and Australia, regulate payday lending. So it’s really about getting ahead of (or alongside) regulation rather than CSR, isn’t it?
critiquing consumer surveys May 5, 2016Posted by Bradley in : consumers , add a comment
This article identifies some of the problems with the endless consumer surveys we are subjected to all the time:
Problems with surveys are two-fold, researchers said. First, too many surveys with too many questions turn off consumers. Second, results that are tied to employee bonuses — or jobs — prove inaccurate. Combined, these problems are turning a useful method of interacting with customers into a headache.
But there’s often an additional problem, as the surveys tend to focus on the performance of the people who are actually providing the services. If I book Sears to provide repair services for a washing machine the survey will ask me how happy I was with the service provided by the person who actually came to my home to work on the machine. The surveys control the service providers pretty well. They don’t tend to ask for feedback on how pleasant or unpleasant it is to interact with the firm as a whole rather than the particular individuals you deal with. And if the experience overall is horrible but the person you actually interact with seems to do a good job and is pleasant to deal with, of course you will give them the high score. But this may be misleading.
The article suggests that it can be a problem if customers are effectively “bribed” to give positive feedback. I am not so sure: asking your customers to speak to you before giving you a lower score than 10 so you can persuade them to give a higher score is in some sense about consumer satisfaction.