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ZestCash is not Good.

A couple of days ago, TechCrunch featured a favorable story about a new startup called ZestCash, which provides an online lending alternative to existing payday loans (I’m not going to link to them directly, you can get to them on your own easily enough). The story regurgitates ZestCash’s copy about the evils of the existing payday loan industry, including numbers highlighting just how usurious the sector is. What it fails to mention is ZestCash’s own rates, which run between 242% and 462% APR at the time that I’m writing this.

To put that into perspective, consumer advocates regularly warn against the abusive nature of the ~30% APRs charged by many credit cards. The Center for Responsible Lending, which is frequently mentioned on ZestCash’s website at the time of this writing, supports a 36% annual interest rate cap. To make that point absolutely clear: ZestCash *repeatedly* cites a consumer advocacy group in making the case that they’re a responsible lender, and then turns around and charges rates up to more than 12x those advocated for by that same group.

Beyond the ridiculously high rates, the entire site is filled with disingenuous copy that seems designed to make unsavvy consumers feel smart and responsible for using ZestCash. They claim in big letters on the front page that ZestCash is “up to 50% cheaper than a payday loan”, but you have to click two links deep to find the explanation for where that number comes from, at which point you learn that 50% is over a payday loan that has been “rolled over” 7 times. They have an entire page dedicated to trying to convince you that APR doesn’t really matter. They make a big deal about the fact that they don’t have a lot of extra fees, but the fees they do have are massive: a 30% ‘origination fee’ on every loan, and a $35 late fee per missed payment on top of whatever overdraft fees your bank charges. They make a big deal of the fact that they clearly disclose their terms, but they’re required to do so by federal law. Almost every sentence on their website makes me tremble with rage for one reason or another.

The worst part about all of this is that their marketing message seems to have worked, at least this early on. I learned about them from a tweet by an entrepreneur I admire, which said he liked how ZestCash was trying to do payday loans in a “don’t be evil” way (he seemed to back off this when their rates were pointed out). A twitter search right now shows an overwhelmingly positive reaction, and the coverage of the service from major tech and business sites has been mostly positive as well. What gives? Do people really trust the press release they get from a company that much? Do they not go to the front page of the service and click around at least a little bit? Are Douglas Merrill and Shawn Budde big enough players that nobody’s willing to criticize them? Are their investors? I was similarly confused by the positive reaction to Betterment, a service that launched a little while ago that appears to try to convince consumers that ETFs are just savings accounts with higher returns, but this really takes it to a whole new level.

(ed. note: Betterment is no longer pushing the marketing approach mentioned above as aggressively as when they launched. Thanks, KW)


Thank you. I couldn’t agree more both about ZestCash (which is just a payday loan place) and Betterment (which is akin to buying a couple ETFs, except with additional fees.)

Betterment has since changed their marketing, but their initial marketing was so slimy as to ensure that even if they improve their product I won’t touch them with a ten foot pole.

Posted by KW on 14 October 2010 @ 5pm

Wow, this kind of post can really hurt a startup. Your post is already the 4th link in Google when looking for “ZestCash”.

I will follow the discussion on HackerNews with interest.

Posted by Aymeric on 14 October 2010 @ 6pm

Great post, well worth a useless but supportive comment from me.

Posted by Nathan on 14 October 2010 @ 6pm

Amen! I feel exactly the same. I was surprised to see the positive reaction.

Posted by Lukas on 14 October 2010 @ 7pm

The interest rates are high because the risk is high. Many borrowers simply don’t pay the money back.

If you really think they’re too high, start your own payday loan business and offer your “fair” 36% rate. Be sure to post here again and let us know how it works out.

Posted by Jeffrey Paul on 14 October 2010 @ 8pm

Good job. Somebody has to read the fine print.

Posted by Maintenance Man on 14 October 2010 @ 9pm

Kudos. Just because it’s legal doesn’t make it right. These payday loan practices are shameful.

Posted by Adam on 14 October 2010 @ 10pm

If the risk is high, perhaps the loan should not be made.

Posted by mjc on 14 October 2010 @ 10pm

@mjc: You might get your wish. If a legal price cap went into effect on cars, then BMWs wouldn’t suddenly become “affordable;” rather, they would cease to be sold at all. The same is true for lending.

For some borrowers, having no loan at all might be an improvement over a high-interest loan. For others, it will not.

Posted by Lucas Bergman on 15 October 2010 @ 6am

To what extent is ZestCash’s approach just marketing hype? Are they really just another payday loan operation with “disingenuous” marketing?…

This blog post, if true, is fairly damning: http://jasonfager.com/934-zestcash-is-not-good/…

Posted by Quora on 15 October 2010 @ 8am

Good work! The TC article reads like a sleazy advertisement. But it looks like they are getting raped in the comments.

Posted by Troy on 15 October 2010 @ 9am

I couldn’t agree more. There is so much potential in providing financial services to the un-banked, but only when it is done right!

An uplifting article from the Economist on the financial ingenuity of those with little money: http://www.economist.com/node/13665319?story_id=13665319

(ed. note: I took the liberty of expanding your bit.ly link, I’d rather not have shortened links on my blog. Hope you don’t mind.)

Posted by Demetri Karagas on 15 October 2010 @ 9am

What you seem to be advocating is that consumers that have the highest risk have no credit at all, regardless of circumstances. APR is important, but not the only metric for financial products. Think about the transaction fees alone. Say you wanted to make no profit at all, and assumed a default rate of 0% (basically a perfect world). If you made one payment in and one withdrawal by ACH, you would incur ballpark 50 cents per transaction x 2= $1. On a $200 loan for 14 days that is a simple interest of about 0.5%. The APR on this is just above 13%. This assumes no cost of any kind to close the transaction. If the lender incurs only $2 in transactions cost (or 12 minutes per loan of someones time to process and collect at $10/hr) and passes the cost on to the customer then the APR is already over 39%. That is 39% with zero defaults, minimum transaction costs, and no profit for the lender. If you advocate a 36% APR cap, then you should understand that it is actually impossible to offer credit to anyone like this. BTW, I don’t have anything to do with ZestCash, I just believe in 1) markets 2) that you know what to do with your life better than I do.

Posted by Chris on 15 October 2010 @ 4pm

@Chris

The 14 day term is a big part of the problem. Extend that, and the corresponding APR for the same fee drops pretty dramatically. Term extension is actually the (only) thing that ZestCash gets right, but then they pair that extension with very similar APRs to what’s in the current payday market. So, for instance, their “$400 for 4 months” loan, with an APR of 296%, ends up costing $634.27. You cannot convince me that’s anything other than usury.

Posted by Jason on 16 October 2010 @ 11am

Problem is the longer the duration the more the risk. I don’t believe in usury, so we likely wouldn’t have a productive conversation around that, but what do you think is the cutoff? If its 36% I find it really difficult to make that work for any lower amount in a shorter period. I would agree 100% that it is a bad financial option, but I don’t know what their other options are? If they exist I assume they would take them. The fees do seem to be pretty transparent, and these people seek out the loans so I presume that ultimately they are looking out for their own best interest. If you come up with an alternative way to make money at affordable rates to this population, I would love to hear it (hell, lets go into business together).

Posted by Chris on 18 October 2010 @ 8am

@Chris

I’d need to see some data to agree that longer terms increase risk. Intuitively, I don’t buy it: why would someone be less likely to meet a small installation than a large lump payment?

There are companies trying to make a go at 36% APR, check out BillFloat. The FDIC just finished a pilot program with a group of banks using a 36% APR template, and many are continuing with the program because it helped them pull people up into their traditional banking products.

Posted by Jason on 19 October 2010 @ 7am

@Jason
Generally financial products consider the duration of the loan an added risk. Right now, as a very general example, 10 year treasures offer a yield of 2.51% compared to a 0.36%. I don’t disagree with you about small installations being generally better, that is why rollovers are common. A note on BillFloat, I was a a little unclear about whether they charge 3% a month or 36%APR (there is a difference), but did notice that they charge a fee on top of the APR, making their effective rate substantially higher. And I suspect the reasons were the ones I mentioned, transaction costs are too high to make it feasible. Can you send me a link to any info on the FDIC program? I’m curious to see how it works. Anyway, I’m curious do you advocate a government response or do you just want people to try and find better options? Essentially, I won’t disagree that these loans are a last resort financial tool, and that planning to use them is a bad idea for your long term financial health. My personal beliefs would prevent me from standing in the way of people needing money and people offering money. If the demand for short term consumer credit exists in high risk consumers, how do you satisfy that? Anyway, would like to hear your thoughts on actual improvements. My thoughts would be to eliminate restrictions on credit (such as usury laws) and rigorously enforce contract law to reduce the ambiguity and regulatory costs for lenders so that there becomes more competition at lower costs, lowering rates and increasing options for consumers.

Enjoying the discussion, glad we haven’t resorted to throwing verbal dung at each other. – Chris

Posted by Chris on 19 October 2010 @ 9am

@Chris

I should have been more clear: I’d need to see some data to agree that longer terms on the order of months increase default risk on payday loans. That’s also the scope of the intuition I was referring to. I don’t think you can blindly draw inferences about payday loan metrics from treasury metrics, but show me some data, and I’ll be happy to change my mind.

I honestly hadn’t read BillFloat’s copy closely enough, I was repeating what their CEO claimed on twitter. You’re right, their actual APR ends up being well over 36% – a quick sample bill I just entered ended up at ~75%. I’m curious to know why their marketing is considered on the safe side of the Truth in Lending Act, which specifically states that APRs used for advertising purposes have to be based on the total cost of credit. Anyways, big mea culpa on that, especially in the context of railing on another company for something similar.

The FDIC Small Dollar Loan program report is available at http://www.fdic.gov/smalldollarloans/ They report generally favorable responses from participating banks, but unfortunately no numbers on profitability (they explain why in the report, but it still feels like a pretty glaring omission).

I always prefer a market solution, but I’m not opposed to government stepping in when the market can’t or won’t ethically or economically provide one. This is certainly a hard problem, and I don’t pretend to have any easy answers, but I do think this is a case where the free market has failed to do much more than take advantage of desperate or unsavvy consumers. A handful of states actually have banned payday loans outright, and I’m okay with letting those experiments run for a while. Otherwise, if someone comes in with actual innovation in this space and can make these loans in a fair and ethical way, I will strongly support them.

Posted by Jason on 19 October 2010 @ 11am

@Jason
Interesting program by the FDIC. At the end of the day I’m not sure there is a lot of meat, as you mentioned, as they don’t include returns or creditworthiness of customers. I would guess, without support, that many customers who take payday loans would not qualify for this kind of bank loan.

I also agree that ZestCash is not doing anything really innovative or substantially unique. I honestly think that credit cards are maybe the only way to go for smaller dollar amounts below 36% for the truly high risk (because of the money made on transaction fees).

I don’t have meaningful data regarding the difference between the default rates over weeks or months of time, although intuitively I believe that to be more often true than not. If I come across something I will post it.

At the end of the day, I would be concerned that if the consumer demand is real for high-risk fast-cash type loans, and these are squashed, then customers might go for financial products that are more complicated with with potentially worse affects and/or move to the black market for loans. Essentially, I do not believe at this point that it would even be possible to offer uncollateralized loans to some of these individuals at rates at low APRs. The innovation have to come in transaction fees and underwriting to even make it conceivable. Those that would default will be without credit and enter bankrupcy or other process with any creditors. Maybe technology will get us there.

Posted by Chris on 19 October 2010 @ 12pm

Quick followup re: BillFloat: discussed the APR issue a bit with their CEO, and I’m left feeling a lot better about where the additional cost on top of the interest rate is coming from. Hopefully their messaging evolves soon to convey to their customers what was conveyed to me.

Posted by Jason on 20 October 2010 @ 9am

I read the early industry articles on ZestCash with great interest, and also went to their site to check out the terms of the product. They are doing exactly what the existing payday loan industry is moving towards – small loans with longer terms. Nothing new there, at all.

ZestCash is really no different than any other online payday lender. The major difference, of course, is that the ‘ex-Google exec’ factor is being played up, big time. In other words, they are trying to leverage Google’s brand equity to help launch this company. I wonder if current Google executives are okay with that. But, a pretty smart marketing move, especially since payday loans are becoming more mainstream.

No one has been able to offer small-size, short-term loans for anywhere near 36% APR. The FDIC pilot project started with hundreds of banks participating, and is now down to just a few dozen simply because the banks were losing their shirts on this product. Those left participating are doing so only for the CRA credits and/or the need to market to the under-served and to ‘graduate them’ to bigger bank products. No one in the industry views the FDIC pilot as a success except the FDIC.

If these loans could be offered more cheaply, they would have been. There certainly are no shortage of people wanting to get into the business.

Posted by Pat on 21 October 2010 @ 6am

@Pat

Thanks for the informative comment. Do you have any good pointers on where to find more information about the banks’ perspective on the small dollar loan program? I read the FDIC report, and you’re right, it seems pretty thin on several critical points. The additional reading I’ve done online, though, suggests that banks haven’t been dropping the program because they were losing money on it as much as because they weren’t making as much as they were from overdraft fees and the like.

If you’d like, please feel free to email me, jfager -at- gmail.

Posted by Jason on 21 October 2010 @ 7am

@Jason

Out of curiosity what did billfloat’s CEO say to make you feel better about it? I’m guessing it had to do with transaction costs.

Chris

Posted by Chris on 21 October 2010 @ 7am

@Chris

He asked that the conversation be off the record, so I hesitate to repeat it here. A large part of it was around the transaction costs of last-minute payments to 3rd-party billers, but there was more. He seems pretty accessible, I’d imagine he’d probably be happy to discuss the issue with you as well (@rgoffice on twitter).

Posted by Jason on 21 October 2010 @ 8am