payday greed: how banks and payday lenders profit from minnesotans in need

Payday Greed: How Banks and Payday Lenders Profit from Minnesotans in Need

Introduction

Rat. Dui blamconse vel inciduip enit

veros adionsecte consequip eugiamet





The White Paper Template 1

October 2015

Payday

Greed: How Banks and

Payday Lenders

Profit from

Minnesotans

in Need

ISAIAH

http://www.mnfaireconomy.org/




Table of Contents

Introduction ................................................................................................................................................................ 4

About Payday Loans .................................................................................................................................................. 5

Who Uses Payday Loans ........................................................................................................................................... 6

How Banks Drive Customers to Payday Lenders..................................................................................................... 6

Bank Financing of Payday Lenders ........................................................................................................................... 7

Bank Payday Lending ................................................................................................................................................. 8

Payday Lending and Minnesota Law ........................................................................................................................ 9

Payday Politics ......................................................................................................................................................... 10

The Payday Lending Debt Trap in Minnesota ........................................................................................................... 11

What Can Be Done .................................................................................................................................................... 12

About ISAIAH ............................................................................................................................................................. 12

Appendix - Uniform Commercial Code Filings ......................................................................................................... 13


Introduction

The above slogans are just some of those used

by the two largest payday lenders in Minnesota

-- Payday America and ACE Cash Express -- in

the course of making their high interest, short

terms loans.

Payday lenders made almost 400,000 loans in

Minnesota last year totaling $150 million.1

Payday America and ACE accounted for three

out of every four of these loans.2 Payday

America by itself made nearly half of all

payday loans issued in the state.3

Payday lending in Minnesota is regulated by the

state’s Consumer Small Loan Act, which caps

loan fees and amounts. However, Payday

America and ACE have evaded these

regulations by exploiting a loophole in the law.4

In order to fend off legislative changes aimed at

closing that loophole and providing stronger

protections to consumers, Payday America

owner Brad Rixmann has become one of the

biggest political donors in the state, giving

almost $550,000 in the last decade.5 Payday

America spent $300,000 on lobbying the state

legislature just in 2014.6

Payday lenders maintain that their loans are

meant to help people in a one-time emergency,

but in fact payday loans often sink people

deeper in debt and trap them in extremely

expensive loans.

The average Minnesota payday loan customer

takes out ten loans a year.7 Nearly a quarter of

payday loan customers took out 15 or more

loans.8

Payday lenders exploited a need that banks were

not meeting for their customers. Rather than

changing their practices or developing new

products to better serve their customers’ needs,

banks opportunistically chose to invest in payday

lenders and share in their profits.

Wells Fargo and US Bank have pumped hundreds

of millions of dollars in capital into the payday

loan industry, including providing financing to

Payday America and ACE Cash Express as well as

to other payday lenders operating in Minnesota.

Wells Fargo and US Bank did begin to offer

payday loan products of their own. However,

instead of being an affordable alternative to payday

lenders, Wells Fargo and U.S. Bank charged even

larger fees and higher rates than many payday

lenders in Minnesota.

In 2013, the Office of the Comptroller of the

Currency (OCC) issued guidance to prevent banks

from making small-dollar loans that caught their

customers in a debt trap because they couldn’t

afford to pay the loans back.9 In January 2014, US

Bank and Wells Fargo announced that they were

discontinuing their payday loan products.10

Both banks announced they would be developing

new products. US Bank issued a statement that the

bank was “committed to finding new solutions that

meet the needs of all of our customers and fit

within the current regulatory expectations.”11

However, there has been no action to date.


About Payday Loans

Fifteen years ago, payday lending played only a

marginal role in the economy. Today there are

76 payday loan stores in Minnesota -- three

times more than were in operation in 2000.12

Payday loans are short-term consumer loans for

small amounts. They derive their name from

their due date: the loans need to be repaid on the

day when the customer receives their next

paycheck (or government benefits check).

Payday lenders say their loans are meant to help

people in a one-time emergency, but in fact

payday loans often sink people deeper in debt

and trap them in extremely expensive loans.

Customers must have a bank account. To obtain

the loan, customers must agree to "secure" the

loan by authorizing the lender to make a

withdrawal for the loan amount plus interest

from the customer's bank account on their next

payday.

Payday lenders have built their entire business

on the simple truth that low- and moderate-

income families don't have a lot of money and

are often in need of funds. These lenders

beckon customers with promises of how fast and

easy the process will be (in contrast to the loan

process at a bank).

As ACE Cash Express advertises: 13

Payday lenders don't consider whether the

person can repay a loan before approving it.

There are no credit checks. As long as someone

has an ID, bank account and source of income,

they can get a loan. Payday lenders profit most

when consumers are unable to repay their loans

and so need to take out a new one.14

Most customers can't afford to repay the whole

loan in just a week or two, and if

lender tries to withdraw the money from their bank

account, it will overdraw their account, costing the

customer even more in fees. So instead of

incurring non-sufficient funds fees, the customer

takes out a new loan to pay off the old one, leading

to a cycle of debt that can last for months or even

years.

The Consumer Financial Protection Bureau

(CFPB) found that four out of five payday loans

are rolled over or renewed within 14 days. The

CFPB also found that the majority of all payday

loans are made to borrowers who renew their loans

so many times that they end up paying more in

fees than the amount they originally borrowed.15

In 2014 the Consumer Financial Protection Bureau

(CFPB) took enforcement action against ACE Cash

Express for pushing payday borrowers into a cycle of

debt. The CFPB found that ACE used illegal debt

collection tactics – including harassment and false

threats of lawsuits or criminal prosecution – to

pressure overdue borrowers into taking out additional

loans they could not afford.16

ACE's 2011 training manual includes a graphic

showing the cycle in which customers first receive

the loan, then when they can't repay it, they are

pressured to take out a new loan.

ACE Cash Express Training Manual


Who Uses Payday Loans

It should come as no surprise that payday

loans, with their triple-digit interest rates, are

not used by wealthy consumers. Eighty-one

percent of payday loan customers have a

household income less than $50,000 and half

(forty-nine percent) had household incomes

less than $25,000.17

In addition to low-and moderate income

families, people of color make up a

disproportionate number of payday loan

users. Less than 4 percent of white

households have used payday loans,

compared to 12 percent of African-American

households.18

Those who are separated or divorced are also

more likely to use payday loans. Thirteen

percent of people who are separated or

divorced have taken out payday loans,

compared to seven percent of those who are

single and five percent of those who are

married.19

How Banks Drive Customers to Payday Lenders

Payday lenders exploited a need that banks were

not meeting for their customers. To gain even

more business, payday lenders also made their

product more accessible than traditional bank

products. Almost half of all households that use

payday lenders say they do so because payday

loans are easier to qualify for than bank loans.20

Banks generally do not make small

loans in amounts such as $300 or

$500. Although banks offer credit

cards and lines of credit, many

customers do not know about them

or do not qualify for these products

which have overly strict

underwriting requirements.

Some bank customers say they

have taken out payday loans

precisely to avoid overdrawing

their checking account and having

to pay large non-sufficient funds

(NSF) fees,21

currently $35 for each

overdraft at Wells Fargo and US

Bank.

Rather than developing new products to better

serve their customers' needs, banks such as

Wells Fargo and US Bank opportunistically

chose to invest in predatory payday lenders and

share in the profits.

“Despite the tremendous demand for

small- dollar, unsecured loans, most

products available in the market come

at a high cost to consumers. Banks have

the tools and infrastructure to create

products meeting this need that are

beneficial to both the banks and their

customers.”29

- Sheila Bair, former chair,

Federal Deposit Insurance Corp (FDIC)


Bank Financing of Payday Lenders

Almost all of the major payday lenders receive

their funding from large banks such as Wells

Fargo and US Bank. Payday lenders would not

have the money to lend their customers if they

did not receive financing from banks.

Advance America

Wells Fargo and US Bank have pumped

hundreds of millions of dollars of capital into

the payday loan industry. For instance, in

December 2011, Wells Fargo, US Bank, and

Bank of America together renewed their $300

million line of credit to the biggest payday

lender in the country -- Advance America.22

In 2012 Advance America was purchased by a

Mexican consumer finance company, and Wells

Fargo served as the financial advisor to

Advance America in the sale.23

Wells Fargo has been involved since the very

beginning of the payday loan industry,

providing $40 million with Bank of America in

start-up financing to Advance America.24

Payday America

Payday America is a privately owned

company, which means that very little of its

financial information is publicly available, so

it is not possible to find out the sources of

financing the way one can for publicly-traded

companies. However, when a business

borrows money to purchase equipment and

uses the equipment as collateral, the bank files

a commercial lien, known as a Uniform

Commercial Code (UCC) statement, on the

property.

There are numerous UCC filings from US

Bank, Wells Fargo, and other banks regarding

their commercial loans to Payday America, its

parent company Pawn America, and other

payday lenders operating in Minnesota. For

instance, US Bank has made at least five loans

to Payday America and its parent company

Pawn America since 2009.25

ACE Cash Express

Wells Fargo and US Bank also have a long history

financing ACE Cash Express, the second largest

payday lender in Minnesota.

In 2002 ACE entered into a credit agreement with a

syndicate of banks, including US Bank and led by

Wells Fargo. They extended a $120 million credit

facility to ACE and a $45 million credit facility

available during the year-end holiday season.26

Over the next several years, this agreement was

amended to significantly increase the amount of

credit available to ACE and to lower the interest rate

that ACE had to pay the banks for the credit.

Financing to ACE Cash Express

Year

Max Available

Interest

Rate Revolving

Credit

Facility

Seasonal

Credit

Facility

2002 $120 million $45 million LIBOR

plus 4.0%

200327

$120 million $55 million LIBOR

plus 3.5%

200428


plus 2.50%

200629


plus 2.0%

These agreements brought millions of dollars in fees

to the banks, on top of the interest. ACE paid

upfront commitment fees of:

$1.1 million in December 200230

$1.1 million in February 200331

$1.7 million in March 200332

$800,000 in 200633

These credit agreements were secured by liens on all

of the assets of ACE and its subsidiaries and were in

effect until 2010, at which time they were extended

again until 2015.

In addition, Wells Fargo served as trustee for several

debt financings for ACE:

$175 million of 10.25% senior notes in 200634

$350 million in 11.0% senior notes in 201135


Other Payday Lenders US Bank and Wells Fargo have provided

financing to a number of other large payday

lenders in the U.S.

EZCorp has over 1,400 stores.36 U.S. Bank is one

of the lenders, and Wells Fargo was the

administrative agent, joint lead arranger, and joint

bookrunner for a $175 million credit agreement

issued to EZCorp in 2011.37

Cash America has over 900 stores.38 Wells Fargo,

US Bank and other lenders entered a 2005 credit

3940

41

42.43

Bank Payday Lending

Until 2014, US Bank and Wells Fargo offered

their own payday loan products. However, instead

of being an affordable alternative to payday

lenders, the banks charged even larger fees and

higher rates than many payday lenders in

Minnesota.

US Bank called its payday loan product

"Checking Account Advance" and charged

customers $2 for every $20 borrowed. Wells

Fargo's product was "Direct Deposit Advance"

and charged $1.50 for every $20 borrowed.

The fees may at first seem reasonable, but because

the loan terms are so short (typically 14 days) they

amount to an extremely high Annual Percentage

Rate (APR). For instance, US Bank charged $50

on a $500 loan, which is a 260% APR.

The banks made loans, up to a maximum of $500,

to their checking account customers who had

direct deposit. Wells Fargo and US Bank would

withdraw the loan payment (loan amount plus

fees) directly from the customer's next automatic

direct deposit.

A study by the Center for Responsible Lending

found on average, 44 percent of a bank payday

loan customer's next deposit went toward repaying

the payday loan, which basically forced the

customer to take out another loan to make it to

th 44

45

The study also found that one out of every four

bank payday loan customers was on Social

Security, and that people on Social Security were

almost three times as likely to have used a bank

payday loan as bank customers as a whole.46

In 2013, the Office of the Comptroller of the

Currency (OCC) and the FDIC issued guidance to

prevent banks from making small-dollar loans that

caught their customers in a debt trap because they

couldn’t afford to pay the loans back. In January

2014, US Bank and Wells Fargo announced that they

were discontinuing their payday loan products.47

Both banks announced that they would be

developing new products. US Bank issued a

statement that the bank was “committed to finding

new solutions that meet the needs of all of our

customers and fit within the current regulatory

expectations”48

However, it has now been almost

two years, and there has been no action to date.


Payday Lending and Minnesota Law

Payday America and ACE Cash Express accounted

for three out of every four payday loans made in

Minnesota.49

Payday America by itself made nearly

half of all payday loans in the state.50

Payday Lending Market Share

201451

In Minnesota, payday loans are regulated by the

Consumer Small Loan Act (Minn. Stat. § 47.60).

The maximum size of a loan permitted under the

act is $350 and the maximum fees that may be

charged are $26.

However, Payday America and ACE Cash

Express found a loophole so as not to be bound by

the maximum loan or fee limit. These companies

circumvent the state law by registering as

industrial loan and thrifts.

As an industrial loan and thrift, these lenders make

their loans under a different Minnesota statute

§47.59. Under this statute, lenders can charge a

33 percent interest rate plus a $25 administrative

fee on a "closed-end" loan (as ACE does) or 33

percent interest and an annual fee of up to $50 for

an "open-end" loan (as Payday America does).

Payday America and ACE are also able to exceed

the $350 maximum loan amount -- a fact Payday

America touts, "We conveniently offer advances

up to $1,000 - far surpassing the maximum of

many other companies."

Banks charged even higher than allowed under that

loophole. US Bank argued that because it was

chartered nationally by the Office of the

Comptroller of the Currency (OCC), the national

bank pre-emption standards allowed them to

override state law in some circumstances.

Fees and APR on a $350 loan

S

A number of states had enacted restrictions on

payday lending, but US Bank and Wells Fargo

continued to make payday loans in those states,

charging higher fees and rates than permitted by

state law.

Lender Fee APR

Payday America52

$31.43 234%

ACE Cash Express $28.15 210%

Allowed by MN Stat. § 47.60 $26.00 194%

(until January 2014)

US Bank $36.00 268%

Wells Fargo $26.25 196%


Payday Politics

Brad Rixmann owns 26 Pawn America stores and

16 Payday America stores. He said he got

involved in politics about ten years ago when a

number of bills were introduced to close the

payday loan loophole in state law, which would

not have been good for Rixmann's business.53

He quickly became one of the biggest political

donors in Minnesota, giving more than

$540,000 since 2002, about 90 percent of it going

to Republican candidates and committees.54

In

2014 when Democrats controlled both chambers

of the legislature, he made a quarter of his

contributions ($15,000) to Democrats.55

In 2013

gave more to Democrats than to Republicans.56

A bill that would have imposed additional

regulations on the payday loan industry looked as

if would pass in the 2014 legislative session. It

was quickly approved by the House, but then got

bogged down in the Senate. Rixmann had made

contributions of $2,500 to both the DFL and

Republican Senate caucuses on the eve of the

legislature's convening.57

The Senate weakened the bill's restrictions and

then Republican leaders threatened not to support

the bonding bill unless the payday lending bill

was killed.58

The Republican House minority leader said he

opposed the bill because he felt it targeted

Rixmann as a major Republican donor.59

Rixmann has also been involved in politics

beyond simply writing checks. In a 2012

Minneapolis-St. Paul Business Journal profile

about "A Day with Pawn America's Brad

Rixmann," he received a call from House Speaker

Kurt Zellers, and the two talked for fifteen

minutes about redistricting and fundraising.

Rixmann was finance co-chair of the 2010 Tom

Emmer for Governor campaign and of the 2014

Kurt Zeller for Governor Campaign Finance

Committee.60

Rixmann is also the chair of the Minnesota Pawn

Brokers Association, and his government affairs

director is the chair of the Minnesota Retailers

Association. The Retailers Association's board is

made up of lobbyists from other retailers

including Target, Walmart, the Mall of America,

Best Buy, and McDonalds franchisees.

The Retailers Association opposed raising the state

minimum wage above the federal amount and

opposed indexing the wage to inflation. Its 2015

Legislative Priorities included preempting cities and

counties from implementing minimum wages higher

than the state's.

The Association also opposed legislation that would

require businesses to provide paid time off if their

employees or their relatives become ill. The

Association “believes that retailers are best suited to

establish wages and benefits in the workplace, and

opposes a workplace sick leave mandate.”

The Retailers Association is also opposing efforts at

the city level in Minneapolis to provide paid time

off for illness and to require fair scheduling

practices.


The Payday Lending Debt Trap in Minnesota

Most payday loan customers can't afford to repay their

loan in full and meet their other basic needs until their

next paycheck, and since payday lenders do not allow

customers to repay their loans in installments, the

customers end up taking out additional loans and paying

the associated fees. This is how they end up caught in

the debt trap.

Only fifteen percent of payday loan customers have

the means to repay the loan within two weeks.61

The

other eight-five percent of customers must renew or

roll over their loan.

The CFPB found that the majority of all payday loans

are made to borrowers who renew their loans so many

times that they end up paying more in fees than the

amount they originally borrowed.62

Top ten Minnesota cities based on 2012

payday loan volume63

This means that the vast majority of loans made in

Minnesota are not providing customers with

access to new credit, but are essentially just paying

off old credit and costing the customer new fees

each time.

While this is a problem that affects all of

Minnesota, there are certain communities that are

impacted more than others.

As shown in the chart below, payday loan stores

are concentrated in specific areas.

City Payday

America

ACE Cash

Express

Other

Lenders

TOTAL

2012 LOANS

St. Paul $961,000 $438,000 $101,000 $1.5 million

Bloomington $869,000 $92,000 $39,000 $1.0 million

Burnsville $992,000 N/A N/A $992,000

Robbinsdale $968,000 N/A N/A $968,000

Rochester $797,000 N/A N/A $820,000

Minneapolis $398,000 $272,000 N/A $770,000

Fridley $743,000 N/A N/A $743,000

Brooklyn Center N/A $614,000 N/A $614,000

Anoka $572,000 N/A $26,000 $598,000

St. Cloud $404,000 N/A $51,000 $455,000


What Can Be Done

1) The Consumer Financial Protection Bureau

(CFPB) should implement consumer protections

regarding the length of loans and "roll over" or

"back-to-back" provisions to keep payday lenders

from ensnaring consumers in a debt trap.

2) The Minnesota State Legislature should finally

pass strong regulations on payday lending to

protect Minnesota consumers from abusive

practices.

3) Congress should enact a 36 percent rate cap on

all lending. Congress protected military personnel

from predatory payday lenders by passing a 36

percent cap on annual interest. It should extend this

to loans to non-military.

4) US Bank and Wells Fargo should stop providing

financial backing to predatory payday lenders. The

banks should instead start offering affordable,

small loan products that meet the needs of their

customers and should provide funding to programs

that help people escape the payday debt trap, such

as Exodus Lending.

5) The Minnesota Retailers Association should

remove the Pawn America representative as the

organization's chairperson. The Association

opposes a higher minimum wage. Pawn America

and Payday America have a direct self-interest in

keeping working people impoverished. Their

business model is based on people not being able

to make ends meet.

6) Payday loan customers who are caught in the

payday loan debt trap should contact Exodus

Lending, an initiative of Holy Trinity Lutheran

Church in Minneapolis. The program refinances

payday loan debt and allows the borrower to

repay the loan at zero-percent interest over an

appropriate period of time.

Visit http://www.exoduslending.org/

About ISAIAH

ISAIAH is a vehicle for congregations, clergy, and

people of faith to act collectively and powerfully

towards racial and economic equity in the state of

Minnesota. www.isaiahmn.org

http://www.exoduslending.org/


Appendix - Uniform Commercial Code Filings

Debtor Lender Date

Payday America/Pawn America

US Bank 11/26/14

US Bank 8/27/13

Drake Bank 8/23/13

Venture Bank 5/24/13

People's Bank of Commerce 1/25/13

US Bank 9/18/12

Western National Bank 5/24/12

Capital Bank 5/24/12

First Minnetonka City Bank 1/4/12

Signature Bank 12/13/11

Venture Bank 12/5/11

US Bank 7/29/11

Private Bank 9/30/10

US Bank 10/27/09

Western Bank 8/27/09

Unloan Company/

Unbank Company

MB Financial Bank 3/27/13

US Bank 4/11/13

Wells Fargo 8/16/11

MB Financial Bank 4/2/13


End Notes 1 "Minnesota religious leaders to campaign for payday lending reform," Star Tribune, Ricardo Lopez, August 18, 2015

2 "Myths and Facts about Payday Lending," Minnesotans for Fair Lending, April 2014

3 "Leader in payday loans makes his presence felt at Minnesota Capitol," Star Tribune, Ricardo Lopez, August 10, 205

4 "History repeats itself: A new generation of payday lenders exploit a legal loophole to pick Minnesotans' pockets," Ron Elwood and

Kari Rudd for Legal Services Advocacy Project, February 2010, pp. 3 and 8 5 Star Tribune, August 10, 2015

6 Ibid

7 "Hotdish Politics: Payday lenders in the cross hairs," Star Tribune, Abby Simmons, April 5, 2014

8 "Demand for high-interest payday loans soars in Minnesota," MinnPost.com, January 28, 2013

9 "Wells Fargo, US Bank to end deposit advance loans, citing tougher regulation," Washington Post, Danielle Douglas, January 17,

2014 10

Ibid 11

Ibid 12

"Payday Lending in Minnesota: 2014 and Cumulative Statistics," Minnesotans for Fair Lending based on reports filed with the Minnesota Department of Commerce, 2015 13

https://www.acecashexpress.com, accessed October 6, 2015 14

"Payday Loans, Inc: Short on Credit, Long on Debt," Uriah King and Leslie Parrish, Center for Responsible Lending, Executive Summary, March 31, 2011 15

"CFPB Takes Action Against ACE Cash Express for Pushing Payday Borrowers into Cycle of Debt," Consumer Financial Protection Bureau press release, July 10, 2014 16

Ibid 17

"Payday Lending in America: Who Borrows, Where They Borrow, and Why," Pew Charitable Trusts, July 2012 18

Ibid 19

Ibid 20

"FDIC National Survey of Unbanked and Under-banked Households," December 2009 21

"Customers Use Payday Loans for Emergency Expenses," Jason Mikula, March 2, 2012 22

National People's Action, January 2012 23

"Advance America Surges on Mexican Billionaire's Takeover Bid," Bloomberg.com, February 16, 2012 24

"The Predators' Creditors: How the Biggest Banks Are Bankrolling the Payday Loan Industry," National People's Action and Public Accountability Initiative, 2010 25

See Appendix 26

ACE Cash Express Form 10-Q, filed May 12, 2003 27

Ibid 28

ACE Cash Express, Form 10-K, filed August 29, 2006 29

Ibid 30

ACE Cash Express Form 10-Q, filed May 12, 2003 31

Ibid 32

Ibid 33

ACE Cash Express, Form 10-K, filed August 29, 2006 34

"ACE Cash Express, Inc. Announces Earnings Conference Call for Noteholders to Discuss Quarter Results," company press release, November 11, 2013 35

Ibid 36

"EZCorp Names New Chief Financial Officer," company press release, March 2, 2015 37

$175,000,000 Credit Agreement among EZCorp, Inc. as Borrower, the lenders party hereto and Wells Fargo Bank National Association as Administrative agent, May 10, 2011 38

http://www.cashamerica.com/AboutUs/CompanyHistory.aspx, accessed September 2015 39

Commitment Increase Agreement dated as of February 9, 2008 40

Ibid 41

Sixth Amendment to Credit Agreement by among Cash America International, Inc., the lenders party hereto, and Wells Fargo Bank, National Association as administrative agent for the lenders, December 23, 2014

https://www.acecashexpress.com/

http://www.cashamerica.com/AboutUs/CompanyHistory.aspx


42

https://www.qcholdings.com/whoweare.aspx, accessed September 2015 43

Third Amended and Restated Credit Agreement among QC Holdings, Inc. and the Lenders that are Parties hereto and U.S. Bank National Association,, as agent, sole book runner, and lead arranger, July 23, 2014 44

"Big Bank Payday Loans: High-Interest loans through checking accounts keep customers in long-term debt," Center fo Responsible Lending, July 2011 45

Ibid 46

Ibid 47

Washington Post, January 17, 2014 48

Ibid 49

"Myths and Facts about Payday Lending," Minnesotans for Fair Lending, April 2014 50

"Leader in payday loans makes his presence felt at Minnesota Capitol," Star Tribune, Ricardo Lopez, August 10, 2015 51

Minnesotans for Fair Lending, 2015 52

Payday America fee schedule and APR calculations based on a 14 day loan term 53

"Rixmann a growing force among political donors," Politics in Minnesota, Briana Bierschbach, November 9, 2011 54

Star Tribune, August 10, 2015 55

http://www.startribune.com/explore-13-years-of-a-payday-lender-s-political-spending/321085891/ 56

Ibid 57

http://www.startribune.com/leader-in-payday-loans-makes-his-presence-felt-at-minnesota-capitol/321143221/ 58

Ibid 59

Ibid 60

"A day with Pawn America's Rixmann," Minneapolis-St. Paul Business Journal, John Hageman, January 13, 2012 61

"Most payday loan borrowers get stuck in "revolving door of debt," Los Angeles Times, Jim Puzzanghera, March 24, 2014 62

"CFPB Takes Action Against ACE Cash Express for Pushing Payday Borrowers into Cycle of Debt," Consumer Financial Protection Bureau press release, July 10, 2014 63

Minnesota Department of Commerce

https://www.qcholdings.com/whoweare.aspx

payday greed: how banks and payday lenders profit from minnesotans in need

Documents