Consumer Credit Research Foundation (CCRF) is a payday lending industry-funded front group that has commissioned pro-industry academic research at University’s around the country. It is led by Hilary Miller, a lawyer for payday lender Dollar Financial Group (which funds CCRF) and its subsidiaries and a signatory on the SEC forms of dozens of companies, many of them payday lenders.
In 2015, Campaign for Accountability released an explosive report revealing how the industry-backed CCRF finances and influences “academic research.” It outlined how the organization paid nearly $40,000 to a professor from Arkansas Tech University to produce a study claiming that payday loans do not leave consumers trapped in cycles of debt. It also highlighted how CCRF chairman Miller received and edited drafts of the study and encouraged the professor to omit elements that would point to the dangers caused by payday loans. The report also disclosed how Miller dictated and financed media strategy for the release of the study. When contacted by media about the damning report, Miller refused to comment.
According to a report from Freakonomics, CCRF is fighting the release of internal emails from a different university where it also paid for academic research. As Freakonomics notes, this study from Kennesaw State University included a sentence that was “nearly identical” to a sentence included at Miller’s request in the aforementioned Arkansas Tech University study.
CCRF chairman Miller is a staunch defender, even laughably so, of the payday industry. He once disagreed with a Senator who said a 390% APR was unconscionable. He has also said that payday loans are not “unfair” or “abusive” despite triple digit APR’s and that such loans are expensive just like food from 7/11. Responding to criticism over the overwhelming percentage of payday loan borrowers who find themselves trapped in a cycle of debt taking out loan after loan, Miller said people rollover their loans for the hell of it, not because they can’t afford to pay
Privately, Miller concedes “very few” borrowers repay their loans, writing in a private email obtained as part of an open records request, “consumers mostly either roll over or default, very few actually repay their loans in cash on the due date.”
Consumer Credit Research Foundation (CCRF) Funds Pro-Payday Lending “Academic” Articles
- Consumer Credit Research Foundation Provides Links On Their Website To Numerous Academic Studies They’ve “Underwritten In Whole Or In Part” That Are All Supportive Of The Payday Lending Industry. [creditresearch.org]
- They Even Sell Them! “Hard copies of the aforementioned studies and reports are available for purchase. Please contact Consumer Credit Research Foundation for more information.” [creditresearch.org]
CCRF Is Funded by Payday Lender Dollar Financial Group…
- The Consumer Credit Research Foundation Is Funded by Dollar Financial Group. “In a related study released Wednesday, the Consumer Credit Research Foundation said it would be cheaper for customers to use payday lenders than to bounce checks. Payday lenders are subject to more disclosure requirements when they make a loan, the study said. A CCRF official says the foundation is funded by Dollar Financial Group, which owns several payday lending operations, and other companies.” [American Banker, 6/10/05]
…and Run by a Payday Lending Industry Lawyer Who Is Also the Lawyer for Dollar Financial Group and Subsidiaries
- Hilary Miller Was Listed as Chairman of CCRF On The 990 Tax Forms of the Organization. [CCRF, 2012 IRS Form 990]
- Hilary Miller Is Listed as President of the Payday Loan Bar Association. [Martindale.com]
- Hilary Miller Is a Lawyer for Dollar Financial Group and Their Subsidiaries and Has Been a Signatory On the Following Company SEC Forms: [SECInfo.com]
- 1100591 Alberta Ltd.
- 656790 B.C., Ltd.
- Advance Canada Properties, Inc.
- Advance Canada, Inc.
- Albuquerque Investments Inc.
- Any Kind Check Cashing Centers Inc.
- Cash Unlimited of Arizona Inc.
- Check Mart of Florida, Inc.
- Check Mart of Louisiana Inc.
- Check Mart of New Jersey Inc.
- Check Mart of New Mexico Inc.
- Check Mart of Pennsylvania Inc.
- Check Mart of Texas Inc.
- Check Mart of Utah Inc.
- Check Mart of Washington DC Inc.
- Check Mart of Washington Inc.
- Check Mart of Wisconsin Inc.
- DFC Global Corp. [Formerly Dollar Financial Corp]
- DFG Canada Inc.
- DFG International Inc.
- DFG Warehousing Co Inc.
- DFG World Inc.
- Dollar Financial Group Inc.
- Dollar Financial Insurance Corp
- Dollar Insurance Administration Corp
- Financial Exchange Co of Michigan Inc.
- Financial Exchange Co of Ohio Inc.
- Financial Exchange Co of Pennsylvania Inc.
- Financial Exchange Co of Pittsburgh Inc.
- Financial Exchange Co of Virginia Inc.
- LMS Development Corp
- Loan Mart of Oklahoma Inc.
- Manor Investment Co Inc.
- Monetary Management Corp
- Monetary Management Corp of Pennsylvania
- Monetary Management of California Inc.
- Monetary Management of Maryland Inc.
- Monetary Management of New York Inc.
- Money Card Corp.
- Money Mart Canada, Inc.
- Money Mart CSO, Inc.
- Money Mart Express Inc.
- MoneyMart Inc.
- National Money Mart Co
- Pacific Ring Enterprises Inc.
- PD Recovery Inc. [Formerly QTV Holdings Inc.]
- US Check Exchange LP
Miller Has Also Represented the Payday Lending Industry’s Special Interest Trade Group
- Hilary B. Miller Represented The CFSAA And Wrote A Letter To The CFPB On Behalf Of The CFSAA Criticizing A CFPB Report On The Payday Lending Industry. “The Consumer Financial Services Association, which represents payday lenders, is contesting a report on the payday industry published by the Consumer Financial Protection Bureau in April. The dispute likely foreshadows a coming battle over the loans, which the CFPB may propose to regulate. Payday loans, which typically last two weeks, are offered by storefront and online lenders as a way to deal with unexpected financial problems. They have long been criticized by consumer-advocacy groups for pulling consumers into unsustainable debt. Many consumers “end up in cycles of repeated borrowing and incur significant costs over time,” the CFPB said when the report was released. But the payday-loan trade group, in a formal letter of protest filed with the CFPB on Thursday, challenged the regulator’s analysis, arguing that it overemphasized the problem of consumers’ repeat use. The CFPB’s analysis of 15 million loans concluded that 48% of borrowers took out more than 10 loans over 12 months, and only 13% took out two or fewer. But payday lenders argue that usage is less frequent. They point to other data, such as a South Carolina study of their industry that found 32% of borrowers took out at least 10 loans, while 23% took out two or fewer over a one-year period. The CFPB’s report “effectively oversamples the heaviest users and under-samples those borrowers whose use is short and non-recurring,” Hilary B. Miller, a lawyer representing the payday-lenders group, wrote in the letter. “The effect of this error is a massively unrepresentative sample which is nevertheless used to generalize about the repayment experience of the entire universe of payday borrowers.” A CFPB spokeswoman declined to comment. [Wall Street Journal, 6/21/13]
- Miller Testified Before Congress As A Representative Of The Payday Loan Bar Association And The CFSAA. “Mr. Miller. Thank you, Mr. Chairman and Members of the Committee. It is a pleasure and honor to be here today. My name is Hilary Miller and I am here both as an expert on subprime lending and also on behalf of the payday advance industry’s national trade association, the Community Financial Services Association of America or CFSA. Both the Payday Loan Bar Association, of which I am President, and CFSA subscribe to the highest principles of ethical and fair treatment of borrowers. CFSA represents the owners of approximately half of the estimated 22,000 payday advance retail outlets in the United States. CFSA has and, importantly, enforces among its members responsible industry practices and appropriate consumer rights and protections, including special protections for the benefit of military personnel. [Senate Banking Committee, 9/14/06]
Internal Emails Exposed Miller’s Work to Edit and Shape the Supposedly Independent CCRF-Financed Academic Research at One University. Meanwhile, Miller Is Suing to Block the Release of Emails from Another University Where CCRF Funded a Pro-Industry Study
- Internal Emails Obtained As Part of a Public Records Request, Expose How Miller Financed and Edited an Ostensibly Independent Academic Study Supportive of the Payday Industry From Arkansas Tech University. “Internal Arkansas Tech University documents reveal a close working relationship between the payday lending industry and the author of a key academic paper. The Consumer Credit Research Foundation (CCRF), an industry trade group, paid a professor at the Arkansas Tech University College of Business, nearly $40,000 to produce the study, and CCRF’s chairman edited the study and directed the professor to remove negative information. Unsurprisingly, the paper concluded payday loans are not responsible for a “cycle of debt,” an important industry talking point.” [Campaign for Accountability, 11/2/15]
- The Internal Emails Concerning the CCRF-Funded Arkansas Tech University Study Show:
- CCRF paid an Arkansas Tech University professor at least $39,912 to prepare a report entitled, “Do Payday Loans Trap Consumers in a Cycle of Debt?”
- CCRF’s Miller received and edited drafts of the study, and directed the professor to remove negative information about payday lenders from the report.
- When it was discovered payday loan borrowers often had massive debit card overdrafts the month before seeking a payday loan, emails indicate Miller was not “happy” about the finding and stated the information was not the “objective of the study.” The professor agreed not to include it in the report.
- Miller instructed the professor to delete any acknowledgement of the role played by representatives of payday lenders in producing the report.
- Miller dictated and financed the press strategy for the report. In an email to the professor Miller instructed him to identify Arkansas Tech as the source for a PR Newswire release, and the professor agreed.
- Most Recently, CCRF Financed a Kennesaw State University Study That Casts Doubt On Payday Loans Being Harmful To Consumers. “A new study conducted by a Kennesaw State University professor casts doubt on the claims of payday loan critics that extended refinancing of these loans is harmful to consumers’ financial welfare. The study, which was commissioned by the Consumer Credit Research Foundation and based on the transactions of 37,000 borrowers over a four-year period, also found that borrowers who live in states with fewer refinancing restrictions fare better than those in more heavily regulated states.” [Kennesaw State University Release, 12/9/14]
- Jennifer Priestly Was Awarded A Grant Of $30,000 By The Consumer Credit Research Foundation For Her Report On Payday Loan Users; The Grant Was Over Double Her Next Largest Grant In FY 2014. [Kennesaw Funded Grants And Contract FY 2014 (7/13-6/14)]
- CCRF Took Legal Action to Block a Public Records Request for Emails Between Miller and CCRF-funded Kennesaw State Professor Priestly. “When the Campaign for Accountability filed a freedom of information request last year for [the Kennesaw State University professor]’s e-mails, CCRF took legal action against the University System of Georgia to block their release.” [Freakonomics, 4/6/16]
- Freakonomics Found “A Nearly Identical Sentence” in the CCRF-Funded Arkansas Tech Study and the CCRF-funded Kennesaw State Study. “However, there is one familiar sentence in [the Kennesaw State University] paper that suggests Miller may have had a hand in writing parts of it as well. It appears in a footnote on page 8.”… “A nearly identical sentence appears in [the Arkansas Tech University] paper in the section written by Miller that we examined above.” The sentence in question was originally written by Miller. [Freakonomics, 4/6/16]
CCRF Led by The King of Out of Touch Comments on Payday Lending
CCRF’s Miller Disagreed with Senator Who Said 390% Apr Was Unconscionable in Senate Hearing
- Miller Said He Disagreed With The Suggestion By Senator Martinez That 390% APR On A Loan Was “Unconscionable”; Miller Also Said He Thought Payday Loans Could Be “Very Helpful” To 18 Year Old’s With Financial Problems. “MARTINEZ: But you wouldn’t disagree that a 390 percent loan is unconscionable. MILLER: I would disagree with you, sir. MARTINEZ: You would disagree? You think that’s a fair rate of lending and that that is not going to drive someone to financial ruin, if they’re paying that kind of interest rate, particularly when they’re working on a fairly modest salary scale in the first place? MILLER: I respectfully disagree with you. MARTINEZ: You think an 18-year-old taking a loan for 390 percent is conscionable? You can really with a straight face tell me that that is in fact what you believe? MILLER: I believe that used for its intended short-term purpose, that loan can be very helpful to bridge financial problems that an 18- year-old might have and… MARTINEZ: Have you ever been through a credit counseling place, where people counsel folks on credit counseling and how to avoid financial difficulties and such as that? I mean, do you think anyone ever in a credit counseling session would recommend to someone go get yourself a loan at 390 percent interest rate? MILLER: I don’t know. I’m not familiar with how credit counseling operations… MARTINEZ: You should become familiar. Your organization should become familiar. Because our service men and women need to become familiar, and part of avoiding this kind of unconscionable problem would be for them to be better informed on issues of financial literacy, and I think that’s one of the areas where we really should focus. But I also don’t understand how a credible organization, purporting to serve the public interest, could suggest that loans at those rates of interest are really in the best interest of our service men and women. Thank you.” [U.S. Senate Committee on Banking, Housing and Urban Affairs Holds a Hearing on the Department of Defense’s Report on Predatory Lending Practices Directed at Members of the Armed Forces and Their Dependents, September 14, 2006]
CCRF’s Miller: Payday Loans Aren’t “Unfair” or “Abusive” Despite Triple Digit APR’s
- Miller: Despite The Cost Of Payday Loans “Is Neither ‘Unfair’ Nor ‘Abusive’ Even Though The Interest Rates On Such Loans (Expressed As An Annual Rate) Are Nearly Universally In The Triple Digits.” Miller said in a Congressional hearing, “In the case of payday loans, the cost of credit, standing alone, is neither “unfair” nor “abusive,” even though the interest rates on such loans (expressed as an annual rate) are nearly universally in the triple digits.” [Statement of Hilary B. Miller President, Payday Loan Bar Association, Committee on Senate Banking, Housing and Urban Affairs, September 14, 2006]
CCRF’s Miller Privately Admits “Very Few” Borrowers Repay Their Loans
- Huffington Post Reported on Miller’s Candid Admission. Miller concedes “very few” borrowers repay their loans, writing in a private email obtained as part of an open records request, “consumers mostly either roll over or default, very few actually repay their loans in cash on the due date.” [Huffington Post, 11/2/15]
CCRF’s Miller: Payday Loans Are Expensive Like Food at 7/11
- Miller: Payday Loans Are “Expensive” For The Same Reason That Small Quantities Of Food From 7/11 “Cost More Than The Same Items Purchased In Bulk From Sam’s Club.” Miller said in a Congressional hearing, “Payday loans are thus “expensive” for the same reason that, for example, small quantities of food, available on a 24/7 basis from 7-Eleven, cost more than the same items purchased in bulk from Sam’s Club during regular business hours.” [Statement of Hilary B. Miller President, Payday Loan Bar Association, Committee on Senate Banking, Housing and Urban Affairs, September 14, 2006]
CCRF’s Miller: Payday Loans Enhance Borrower’s Economic Welfare
- Miller: “There Is No Evidence Payday-Loan Pricing Causes Economic Harm” But Rather “Borrowers Economic Welfare Is Generally Enhanced.” Miller said in a Congressional hearing, “There is no evidence that payday-loan pricing causes economic harm. Indeed, borrowers’ economic welfare is generally enhanced, rather than reduced, as a result of such borrowing.” [Statement of Hilary B. Miller President, Payday Loan Bar Association, Committee on Senate Banking, Housing and Urban Affairs, September 14, 2006]
CCRF’s Miller: People May Rollover Loans Just for the Hell of It, Not Because They Can’t Pay
- Miller: The DOD Report And CRL Report Assume That Borrowers Rolled Over Loans Because They Were Unable To Pay Them But “This Conclusion Is But One Of Many Possible Conclusions Why Borrowers May Choose To Extend The Maturity Of Their Loans.” Miller said in a Congressional hearing, “Both CRL (and the author of the DoD Report) assume, without factual basis, that the reason all payday loans that have been renewed, or “rolled over,” is that the borrowers were unable to repay them. This conclusion is but one of many possible conclusions why borrowers may choose to extend the maturity of their loans. None of the academic literature in this field addresses the reason for “rollovers.” [Statement of Hilary B. Miller President, Payday Loan Bar Association, Committee on Senate Banking, Housing and Urban Affairs, September 14, 2006]