Fringe Lending in Australia – An Overview

Transcription

Fringe Lending in Australia – An Overview
Fringe Lending in Australia – An Overview
February 2008
Introduction
NAB has commenced a program to shed some light on the fringe lending industry with an industry
participant
The aim is to prove the viability of what it costs to deliver a break-even small loan by having a breakeven product in the market as a commercial proposition.
Loans will be offered in the range of $1000 to $5000 at the lowest possible interest rate to recover costs
The loans form part of NAB’s leadership and product innovation for providing fair and affordable credit
to disadvantaged & financially excluded groups
This report provides a summary of publicly available information on Fringe Lending in Australia
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Scope
Contents
Regulations in each State
Executive Summary……………………………………………………….4
Snapshot …………………………………………………………………..5
Main players & their economics
What is Fringe Lending? …………………………………………………7
Market Size
Benefits/Criticism
Profile of Borrowers/Lenders
Typical Terms
Examples
Typical terms for Fringe Lenders
Academic or Policy research
Regulations ……………………………………………………………….16
“Benefits" of Fringe lending
Comparison of Lending rates
across Industry
Major Players ……………………………………………………………..20
Cash Converters
Amazing Loans
Cash Stop
Bibliography ………………………………………………………………26
Appendix 1: Community Development Finance . .………………………27
NAB – Step-up Loans
ANZ – Progress Loans
Appendix 2 State Regulations …………………………………………....32
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Executive Summary
The providers of credit in the credit industry can be divided into ‘mainstream credit providers’ and ‘fringe credit
providers’. The former are made up of banks, building societies, credit unions and national finance companies.
The latter refers to all those credit providers on the fringe of the credit industry, such as payday lenders, providing
small personal loans, usually for amounts up to $5000, often to people excluded from access to mainstream
personal credit.
Fringe lending is a fast growing part of Australia's financial services landscape.
Fringe lending is typically accessed by low income customers who are excluded from borrowing from
mainstream lenders due to income level, urgent need of funds or failure to meet credit standards of banks.
Interest rates are regulated in some states to an annualised percentage rate of 48% which may or may not
include fees. Interest rates in the hundreds of % are not uncommon where rates are unregulated.
This has lead to criticisms about the predatory nature of the fringe lending market and its ability to add to the
financial difficulties of people on low income.
The industry itself however points to the essential service that is being offered in the absence of any other
alternative.
Either way there is a lack of transparency around the costs and interest rates charged by fringe lenders in
Australia. A key area of contention that remains is what is a commercially viable interest rate for small loans in
the fringe lending market.
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Snapshot
What Is Fringe Lending?
Credit providers on the fringe of
the credit industry such as payday
lenders. It includes:
Pay Day Loans
Small amounts of money;
<$1000
Loans for <62days,
generally until next payday or
welfare payment
Very high interest rates (e.g.
48% to 1000%)
High fees
Profile
Thriving business, with Market
Size of approx. $800 million
Services borrowers with poor credit
history and no access to mainstream
lending
Benefits/Criticisms
Benefits:
Important, legitimate source of
finance for financially excluded
community
Faster and more accessible loans
Caters for those with an urgent
need for funds for consumption
purpose, or to manage day to day
expenses
Majority of players are small
operators
Criticisms:
Exploitative interest rates
Fuels a debt spiral
Small Personal/Other Loans
Generally loans between
$1000 to $5000
Interest rates around 48%
plus
High fees
Around 1 year terms
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Snapshot
Typical Terms
Regulation
Loans can be secured or
unsecured; secured by car, jewelry,
electrical goods.
Loans can range between $100 to
$5,000 with a fixed fee and term
ranging between one week to one
year.
Rollover facilities are also
provided at a cost of 15%-25% of
amount advanced.
Most of the payment is made
through direct debit.
Account keeping charges range
from $2-$25.
Loan default charges range from
$20-$55.
Termination Fees are also a
common feature.
Establishment Fees are charged
as a percentage of loan.
Most fringe lending is now covered
by the Uniform Consumer Credit
Code (UCCC), however, in the past
this industry was not very highly
regulated, and some lenders still
continue to use loop holes to avoid
the UCCC.
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Other Trends
Prices of small loans are likely to
come down once sophisticated
lenders enter the market and become
more efficient and competitive.
Interest rate caps imposed only in
NSW, Victoria, and the ACT.
Consumer advocates are pushing
for federal regulation and the
introduction of a national interest
rate cap.
Challenge for regulators lies in
creating commercially viable, non
exploitative, short term cash options
for vulnerable consumers.
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What is fringe lending?
Fringe lending is defined as any lending from credit providers on the fringe of the credit industry, such as payday lenders,
providing small personal loans, usually for amounts up to $5000, often to people excluded from access to mainstream
personal credit. Essential features include:
Loans concern themselves with amounts or people not considered "bankable".
Products and services are offered by commercial entities, on a for profit basis.
Typically high interest rates - to cover the suggested costs and to justify the risk of the loan.
The products in this market can also be more specialised and flexible, and include small, short-term loans, payday loans,
rent-to-own arrangements, and other products.
Requires less paperwork, and less hassle than a typical bank loan.
Fringe Loan
Market
Payday loans
Chattel loans
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Personal loans
Short-term loans
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Small Consumer
loans
Title loans
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What is fringe lending?
Pay Day Loans
Small Personal/Other Loans
Payday loans are tailored to immediate personal needs.
Typically small loans to cope with immediate problems or
purchases
Loans below $1,000, normally <$300
Loan Amount : $1,000-$5,000 +
Short term (1-2 weeks or <62 days) advances until the next
payday or welfare payment.
Medium Term Loans (1 to 2 yrs)
Typically based on a fixed price (fees) rather than an interest
rate that builds over time.
Can be secured or unsecured
Interest rates are between 24% to 48% p.a.
Fees when converted to effective interest rates are typically
very high and can go up to 1000% or more.
Establishment Fee: $15 - $450
Typically, borrowers confer direct debit authorisation to
lenders, substantially reducing default risk which ranges
between 2-3%.
Weekly Account Keeping Charges : $2-$25
Typical transaction – Consumer borrows $200 to be
repaid within 14 days for a fee of $50 (i.e. 650% p.a.).
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Market Size
The fringe lending market is a thriving business in Australia, and growing rapidly.
Market Size: Currently, annual turnover estimates for the industry range from between $500m and $800m*,
however, due to the undefined nature of the industry, there is no concrete evidence on the market size. It was
estimated that in 2000, there were 150 outlets with a total of approx. $200 m in outstandings.
Emergence of new players: Anecdotally more and more players are surfacing to compete in the market.
Prices of small loans are likely to come down once sophisticated lenders enter the market and become more
efficient and competitive.
*Jane Searle, ‘Cash in Demand’ BRW August 23-29, 2007, p 36-39
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Benefits of fringe lending as stated by the industry
Meeting ‘low-income’ consumer needs: Consumers with poor credit history and have short-term, urgent
financing needs and no access to mainstream lending.
A legitimate, easily inspected and regulated source of credit, as opposed to an underground, black market or
criminal supplier, who would be the only alternative.
Fringe lenders are faster, more accessible and provide very personalised and professional services.
Fringe lenders provide friendlier services: Clients speak of being treated with dignity and respect regardless of
their financial situation.
Supporting consumers who are wary of credit cards: Some of the consumers prefer the financial security of
borrowing a fixed amount, for a fixed term, with fixed repayment arrangements.
Clear and concise paper work detailing all repayment information in an easy to read format, in accordance with
the Uniform Consumer Credit Code.
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Criticisms of fringe lending as put by consumer advocates
Very few consumers utilise fringe credit for
a ‘lifestyle’ or asset building purposes; fringe
loans are used to buffer shocks created by
large bills and to meet ordinary household
expenses.
Fringe lenders use direct debit for
recovering payments and if these are not
honored, banks charge fees for it ($35
generally) aggravating problems for short
term borrowers.
Fringe lenders do not always, fully and
frankly disclose the terms and conditions of
the loan.
The inability to repay due to financial difficulties,
worsened by the high cost of credit, means that
debtors are forced to rollover their loans or borrow
back-to-back, and incur further fees and charges.
One study has shown, 65% of consumers surveyed
had taken out more than 1 payday loan and the avg.
no. of repeat loans taken out by consumers was 6
over 12 months.*
Consumers are paying up to 63 times more for
credit than mainstream borrowers.
This is despite negligible default rates and lenders’
propensity to extend loan commitments.
Consumer advocates argue that high loan costs
exploit low income groups and further create a debt
trap.
*Dean Wilson, Payday Lending in Victoria – A research report, Consumer Law Centre Victoria, July, 2002, p. 65
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Profile of Borrowers/Lenders
Borrowers
Working poor/Low and fixed income groups: Consumers are typically from low socio-economic groups or financially
excluded, with an urgent need for funds, and do not meet the credit standards of banks.
Major Reasons for borrowing could be:
Insufficient income to cope with living expenses and/or negative shocks to their budget e.g. funds to cover
emergencies, or day-to-day expenses and bills or to manage other debts and repayments
Prefer Fringe Lending to other forms of credit (fringe lenders are faster and more accessible)
Engaging in addictive behavior
Debt trap created by rollovers and multiple loans - Most borrowers roll over their loans a number of times, each roll
over adds more exorbitant charges.
Pawn-broking customer base: Another view among consumer advocacy groups and financial counselors is that fringe loan
consumers come from the pawn-broking customer base. The fact that Cash Converters, who were initially pawnbrokers, now
offer fringe loan services, lends strong support to this claim.
Lenders
Majority of players are small operators: While companies like Amazing Loans and Cash Converters are publicly listed, the
bulk of players operate as small, privately owned businesses.
Regional concentration: Located in poor neighborhoods, and target low-income earners. The bulk of the industry, and the
most exploitative lenders, are said to reside in Queensland, where there is no interest rate cap.
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Typical terms of fringe lending
Loan and condition terms might include interest rates, fees, charges and repayment schedules.
Typical Features of Products
Loans range from as little as $50 to $5,000+
Either secured or unsecured. Can be secured by anything of value, including jewelry, cars, furniture and electrical goods.
Fixed fees applies to most loans. E.g., $30 for every $100 advanced.
Charging interest is common, but not universal.
Loan terms range from one week up to a year.
Storage fees may apply for larger items held as security.
Loan default charges include forfeiting goods, or charges ranging from of $20 to $55. Some include daily charges of
$1.57 per day, or even a fixed default rate of 48% p.a.. This fixed rate does not include bank fees.
Some lenders offer discounts on fees if loans were repaid early.
A minority of lenders offer rollover facilities costing between a fixed $15 rate and 25% of the amount advanced.
Direct Debit is often used to repay loans.
Annual membership fees often apply, ranging from $5 to $50.
Loan establishment fees range from $15 to $450, or even a percentage of the loan value, for each loan.
Termination fees include charges of up to $2,000, depending on loan amount, or 90 days interest on the original amount.
Weekly account keeping charges range from $2 to $25.
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Example of a fringe lending personal loan
Lender Location
South-East Queensland
Date of Contract
January 2005
Amount of Credit
$3323.72
Annual Percentage Rate
240% p.a. Note: The rate is applicable if amount of credit is borrowed for a period of 12 months
Total amount of interest
charges payable
$15,747.10 for the agreed term of loan
The agreed repayment installments are 52 fortnightly payments of $366.75
Repayments
For a total of $19,070.82
Repayments to be made by direct debit
Term of Loan
From 07/01/2005 to 03/01/07
Membership Fees
$25 paid one annually and renewable each year
Loan Approval Fee
Not ascertainable
Lodgement Fee
$90.80
Production Fee
Not ascertainable
Other settlement Service fee
Not ascertainable
Dishonor Fee
For cheques up to $10
Bank Cheque Fee
Up to $10
Duplicate Statement Fee
Up to $5
Default Rate
18.41% until the loan is paid in full
Source: Griffith University - High Cost Loans: A Case for Setting Maximum Rates?
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Why fringe lending can be more expensive than mainstream lending
Fixed Cost of Providing Loans
The fixed labour and operating costs associated with providing a small loan are the same as those for providing a large loan.
With a larger loan principal, the lender can recover costs and earn a profit by charging a lower Annual Percentage Rate over a longer
period of time. Short-term loans must however charge higher rates of interest over short payback periods in order to cover the cost of
the given loan and be profitable.
Smaller loans cost more per dollar borrowed than larger loans even when the efficiencies of an online-only organisation are
considered.
The Short Term of the Loan - Convenience and Bulk Discounts
A demand curve is negatively sloping meaning that as demand increases, the price of a given product falls and suppliers enjoy
economies of scale. The demand for credit is no exception.
High income households demanding larger quantities of credit enjoy a quantity discount while lower income households will pay a
premium.
The Inherent Risk Associated With Providing Unsecured Loans
The fringe lending industry is riskier than most other financial ventures and entrepreneurs must recover their investments and earn a
positive return.
According to Ian Day, General Manager, Cash Converters, “Most customers find it a very valuable service and if rates are capped, it will
cease to exist. Hence prices are necessary to cover costs.”*
*Jane Searle, ‘ Cash in Demand ‘ BRW August 23-29, 2007
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The role of the Uniform Consumer Credit Code
Introduction
The Uniform Consumer Credit Code (UCCC) has been implemented as a Schedule to the Consumer
Credit (Queensland) Act 1994 adopted by all Australian States and Territories by passing the legislation
implementing the same in their jurisdiction.*
As per the Explanatory Memorandum to the UCCC ,the main focus of legislation is ‘truth in
lending’ i.e. focus on disclosure, documentation and communication with borrowers.
Applicability
In the past, the UCCC was not applicable on loans for less than 62 days, however, following the
enactment of the Consumer Credit (Queensland) Amendment Act 2001 and similar legislation passed in the other
States and territories, loans for less than 62 days are now covered under UCCC
- If fees and charges exceed 5% of loan amount
- Interest rate exceeds 24% p.a.
Until recently the fringe sector had utilised the "bill facility" exemption under section 7 of the UCCC, and
therefore any interest rate caps, did not apply. This exemption is no longer available following the enactment of
the Consumer Credit (Bill Facilities) Amendment Regulation (No 1) 2007 (Qld) and similar regulations adopted in other
States. The exemption for bill facilities now only applies to credit for business purposes - the UCCC applies
whenever a bill facility is extended for ‘personal, domestic or household purposes’.
Provisions
Provisions of UCCC require the credit provider to disclose all relevant terms and conditions
including annual interest rates before entering into a contract and ensure that borrowers receive
adequate copies of loan documentation.
There is also a requirement of disclosure of annual interest rates in advertisements.
* Griffith University; High Cost Loans: A Case for Setting Maximum Rates? A Centre for Credit and Consumer Law Background Paper Nicola Howell, page 7
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Summary of State Regulations in Australia
The UCCC operates at a Federal level accepted by all the states and territories in Australia. It focuses on ‘truth in lending’
leaving the non-uniform matters including the cap on the interest rates to be regulated by specific State laws. Courts are given
power to re-open the cases of unconscionable interest rates and charges. The individual state laws are as follows:
State/Territory
Maximum APR* prescribed
by regulation
Inclusion of other fees and charges
in calculation of APR
for the purpose of determining
whether the maximum APR
has been exceeded
Inclusion of other fees and
charges in calculation of APR
for the purpose of disclosure of
APR under section 15 of
the Code
Queensland
48%
Yes
Yes
New South Wales
48%
Yes
Yes
Australian Capital Territory
48%
Yes
Yes
30% for mortgages,48% for all
other credit contracts covered by
the UCCC
No
No
South Australia
No
NA
NA
Western Australia
No
NA
NA
Northern Territory
No
NA
NA
Tasmania
No
NA
NA
Victoria
*APR= Annualised percentage rate
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Critical analysis of legal framework
No Impact of Interest Rate and Other Disclosures
It has been recognised that those who are attracted to fringe lending are vulnerable consumers with no access to mainstream credit
due to factors like unemployment or poor credit ratings. This leaves consumers with no choice to borrow, and disclosure of interest
rates has limited impact on their decision to proceed with loan. This low income group is ready to borrow money from any source
that is willing to lend to them.
Availability of Funding for Civil Action is Limited
Research shows that low income consumers are unlikely to take legal action in relation to loan disputes, on the basis of factors such
as cost , a sense of powerlessness and a fear of acrimonious disputes. The ability of borrowers to bring applications to the court
under the UCCC is limited. The UCCC is a form of private law regulation, relying on consumers to act to protect their own interest.
Avoidance of Regulation
The regulatory framework is not uniform in all the states as the only federal regulations regulating the pay day lending is the UCCC,
which does not provide for “non uniform matters” which include capping of interest rates and charges. There are also state specific
provisions, which include Victoria where there is a cap on interest rates, but not charges.
A loophole that might still be used by unscrupulous lenders - obtaining a business purpose declaration from a borrower stating that
the loan is for business purposes, so that under section 11 of the UCCC, the UCCC does not apply.
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Implications of a national interest rate cap (48%)?
There are proposals for a national interest rate cap. The implications of this would be:
Industry players see it as a threat to their growing position in the fringe lending market.
If rates were capped, the industry believes it would make many businesses unviable. As a consequence, lenders may look for
alternate ways of providing the service.
One way of doing this is through broking arrangements, and use of negotiable instruments such as promissory notes.
Presently, legislators do not know what interest rate is commercially viable due to the lack of empirical data on the industry’s cost
structure. Payday lenders assert that a $200 loan for one month would take 45 minutes to approve, with a 48% per annum cap, would
generate a maximum return of $8, which would be unviable. The same cannot be ascertained for loans of higher amounts such as
$1,000 etc.
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Fringe lending: major players
Cash Converters
Amazing Loans
Fast Access Finance
Money Plus
Cash Plus
Q Loans
Cash Doctors
Cash Stop
City Finance
Key Features
Mostly unlisted, except for Cash Converters and
Amazing Loans
General lack of transparency of key economics
Lack of published interest rates
Located in poor neighborhoods, targeting lowincome earners.
The bulk of the industry, and the most exploitative
lenders, are said to reside in Queensland, due to a
no-interest-cap situation.
Big players have presence all over Australia
through shop fronts and agents.
Most of the players are now offering online
solutions for regular customers.
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1. Cash Converters (CC)
One of the best known short-term lenders in Australia.
Currently has 135 outlets in Australia and is seeking to expand its eight store network
in NSW.
Key Acquisitions
On October 13, 2006, CC acquired MON-E Pty Ltd, which is engaged in back
office support for Cash Converters franchisees’ short term cash advance
activities. Provide loans through MON-E.
On September 29, 2006, it acquired Safrock Group, which is engaged in the
provision of secured and unsecured personal loans. A Safrock contract shows
a 6 month loan for $1000, charged an additional $856 including interest and
fees.
Average Contract: Average Safrock loan is $1500 with a total fee of $926 over 6 – 14
months.
Mostly customers are in the income bracket of $20,000-80,000 p.a.
In NSW, where rates are capped at 48%, Safrock operates under a promissory note
arrangement (bills of exchange and promissory notes fall outside the interest rate cap).
CC also has a cash advance business which offers loans of about $250 for one month.
Acc. to CC this business would be unviable if a cap was enforced.
CC has stores that offer second-hand goods for sale, where you can request such a loan
or you can call them using their 13'CASH' toll-free number. Callers using this service
will be referred to a store closest to their postcode.*
Future Strategy: As a result of the NSW cap, CC, has indicated that they will only
offer small short-term personal loans in Queensland, Victoria and Western Australia,
avoiding NSW on the basis of the new cap.
Goal: As stated by CC, there is a huge market for short term cash loans, and with its
distribution network, it is ideally placed to become the biggest provider of short term
cash loans in Australia.
Origin & Reach
Originated in Perth, Western Australia, in 1984
founded by Brian Cummins and a group of
partners. International expansion includes:
UK in 1992 – an operation that expanded
to 105 stores by 2005.
New Zealand (1993, now 27 stores),
South Africa (1994, 57 stores),
France (1994, 23 stores),
Canada (1995, 24 stores),
Spain (1995, 34 stores)
US (1994, 10 stores)
Malaysia (4 stores) followed
Business Model
Cash Converters International Limited is
engaged in the franchising of second hand and
financial services stores operating under the Cash
Converters name. Country franchise licenses are
also sold to sub-franchisers to allow the
development of the CC brand.
The Company has two business segments:
Franchising : Involves the sale of franchises for
the retail sale of second hand goods and sales of
master licenses for the development of businesses
outside of Australia.
Financing: The financing segment provides loans
to franchisees within Australia.
*Primary research carried out by Infosys Australia employee, while visiting CC office in Victoria
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MON-E Loans
Features and Performance of Product Offered
The amount advanced is usually in the range of $50 to under $1,000, with a loan term of not more than four weeks.
The loan is essentially unsecured, with the customers regular income as the asset to secure the loan.
The paperwork takes about 10-15 minutes to complete, assuming you have the supporting and mandatory paperwork
The average amount loaned is approximately $500-$600, the only way you'll be granted $1,000 is if you earn more than
$100,000 annually. Hence the loan does not usually exceed more than 15% of the customers monthly income.
The funds can be approved if you provide evidence of income and the usual 100 points of identification. Alternatively,
one can offer 'Cash Converters' an asset that is at least thrice the value he intends to borrow or get a cash advance for.
The fee charged for providing the advance is 35% (flat) of the principal advanced. The fee is not time based and
compensates the lender for the high risk and no security nature of the loan.
The money borrowed is directly debited from ones account and this debit is done based upon the frequency of the pay
cycle (weekly, fortnightly or monthly)
There is annual system retention fee of $11.00
Failure to pay based on the agreed frequency warrants a penalty of $16.50 for each and every late payment.*
2006 (ended 30 June)
2007 (ended 30 June)
Total number of loans
439,913
486,590
Total principal loaned
$103,037,193
$124,567,170
Average loan amount
$234
$256
154,458
202,325
Customers
*Primary research carried out by Infosys Australia employee, while visiting CC office in Melbourne
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Safrock Loans
Features and Performance of Product Offered
Secured and unsecured personal loans in the range of $1,000 to $10,000.
The unsecured loans range from $1,000 to $2,000, usually have a term of between four to nine months .
The secured loans range from $2,000 to $10,000, usually have a term of between one to two years.
2006 (ended 30 June)
2007 (ended 30 June)
Total number of loans approved
10,317
16,102
Total number of customers
6,115
9,965
Total value of principal advanced
$15.0 million
$23.5 million
Loan book
$8.5 million
$12.8 million
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2. Amazing Loans
Business Model: The Company is engaged in providing broker facilities
•
to residential mortgages, private equity funding, funds management,
financial planning and loans.
Reach: The Company operates from 24 branches located in Sydney,
Melbourne and Brisbane
Loan Amounts and Repayment Terms
During the reporting period 2007, Amazing Loans refined its
lending criteria and the parameters are now
–
Loans from $2,000 to $20,000
–
Loan Repayments over 4 years on a weekly basis
–
There have been cases reported where interest as
high as $6,437 has been charged for a $4,000 loan,
and $1,192 for a $750 loan.
Acquisitions: As of June 8, 2007, the Company acquired the businesses
of Investment Evolution Limited. Amazing Loans was previously engaged
•
in providing consumer finance in the Australian fringe lending market.
Subsequent to the acquisition of Investment Evolution Limited and its
•
controlled entities, the Company had expanded in activities to include
Broker facilities for Residential Mortgages
Private Equity Funding
•
Funds Management
Financial Planning
Interest Rates
Interest rates in the loans provided by Amazing Loans, in all
states and territories, are regulated by various departments in
these States and departments.
During the reporting period, Amazing Loans, elected to
standardise its interest rates across Australia to a maximum of
47.9% including all fees and charges.
Cost of Loan Capital
Effective from 1 July 2007, Amazing Loans negotiated a
reduction in its loan capital borrowing rate from 14.5% to
10% per annum from Ron Medich Properties Pty Limited.
Focus area: Due to NSW interest cap, the Company would focus on
opening branches in other states, which do not currently have similar
restrictions.
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3. Cash Stop
Cash Stop claims to be an industry leader in the alternative
•
•
financial market.
Cash Stop has 31 branches located throughout Sydney,
•
•
Melbourne, Canberra and South Australia. It has also its
agents throughout Australia.
Products Offered
Cheque Cashing
Pay Day Lending
Term Advance
Settlement Loan
Bond Advance
Personal Loan
Car Loan
Business Loan
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Terms
Advances range from $1,000 to $4,000
Period 3 months, 6 months, 9 months, 12 months for pay
day lending
Period of 90 days for term lending
Requirement:
Stable Employment History
Photo I.D.
Current dated bank history/statement covering 8
weeks
Proof of Address
Land line telephone or mobile
Most recent pay slip
• Other terms and conditions including interest, fees and
other charges are not disclosed
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Bibliography
Joint Consumer Submission, Ministerial Council on Consumer Affairs, Discussion Paper on Long Term Regulation of Fringe Credit
Providers, October 2003
Wilson, Therese, The inadequcy of the current reulatory response to payday lending, (2004) 32 ABLR 159
Wilson, Dean, Payday lending in Victoria - A research report, Consumer Law Centre Victoria Limited, July 2002
Queensland Office of Fair Trading 2000, "Payday lending - A report to the Minister of Fair Trading", QOFT, Brisbane
Field, Chris, "Pay Day Lending - An Exploitative Market Practice", (2002) 21 (1) Alternative Law Journal 36 at 37
Howell, Nicola, High Cost Loans: A Case for Setting Maximum Rates?, 2005, Centre for Credit and Consumer Law, Griffith
University
Willis, Frances, "Pay day lending: the case for regulation of the fringe credit market: Parts 1, 2 and 3", (2005) 27(7), (8) & (9), Bulletin
(Law Society of SA)
Jane Searle, ‘Cash in Demand’, BRW, August 23-29, 2007, p 36-39
Consumer Affairs Victoria website - www.consumer.vic.gov.au
NSW Fair Trading Office website - www.fairtrading.nsw.gov.au
Queensland Office of Fair Trading website - www.fairtrading.qld.gov.au
The Ramifications of regulating Payday Lending in Victoria – Presenter: Roger Ouk
MISC Australia Consumer Credit Report June 2006 - Prepared exclusively for the Department of Justice Consumer Affairs Victoria
http://www.cashdoctors.com.au/uncovering-payday-lending-myths/
http://www.abacus.org.au/credit_unions/creditunion.htm
http://www.cuscal.com.au/
http://www.abacus.org.au/credit_unions/find/cuwebs.html
www.anz.com/aus/values/community/progress_loans.asp
www.amazingloans.com.au/
www.cashconverters.com
www.finance.google.com/finance?q=ASX:AZD
www.finance.google.com/finance?q=ASX:CCV
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