High-Cost Credit

Rent-a-Bank Loans

High-cost lenders often launder their loans through banks to attempt to evade state interest rate limits. NCLC fights the use of rent-a-bank schemes and other evasions, such as misuse of tribal sovereign immunity, by predatory lenders.

High-Cost Rent-a-Bank Loan Watch List

February 26, 2026

At least 45 states and the District of Columbia (DC) cap rates on at least some installment loans. But high-cost lenders are increasingly using rent-a-bank schemes with a small number of rogue banks, which are not subject to state interest rate limits, to evade state rate caps on installment loans and lines of credit.

Read More about: High-Cost Rent-a-Bank Loan Watch List
November 21, 2023
July 12, 2023

Recent

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Comments on the Application to Charter Enova Interim Bank & Acquire Grasshopper Bank

February 27, 2026

High-Cost Rent-a-Bank Loan Watch List

February 26, 2026

New Predatory 100% APR Bank Seeks Trump Administration’s Approval

February 23, 2026

Testimony Supporting Oregon HB 4116 Opting Out of DIDMCA

February 3, 2026

Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2025)

December 19, 2025

Appellate Court Upholds Colorado’s Power to Block Predatory Out-of-State Bank Loans

November 10, 2025

Testimony in Support of Rhode Island H 6055 on Interest and Usury

April 24, 2025

Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2024)

November 21, 2024

EGRPRA Comments to FDIC on Interest Rate Authority

October 30, 2024

Comments & Letters

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Comments on the Application to Charter Enova Interim Bank & Acquire Grasshopper Bank

February 27, 2026

EGRPRA Comments to FDIC on Interest Rate Authority

October 30, 2024

Comments on Risks of Bank-Fintech Arrangements Involving Lending

October 30, 2024

Coalition Comments to FDIC Regarding Community Reinvestment Act Examination of First Electronic Bank

March 21, 2023

Coalition Comments to FDIC Regarding Community Reinvestment Act Examination of Rent-a-Bank FinWise Bank

March 14, 2023

Joint Letter to the FDIC Regarding the Community Reinvestment Act Examination of TAB

June 30, 2022

Petition to the FDIC Regarding the Community Reinvestment Act Examination of TAB

June 30, 2022

Coalition Letter Urging FDIC to Stop Permitting its Supervised Institutions to Front for Predatory Lenders

February 4, 2022

Group Comments to Bank Regulators on Third-Party Risk Management Guidance Urging an End to Rent-a-Bank Schemes

October 18, 2021

Reports

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Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2025)

December 19, 2025

Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2024)

November 21, 2024

Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2023)

November 21, 2023

Report: Predatory Lenders TAB Bank & Easypay Finance Harm Veterans & Military Servicemembers

May 24, 2022

Predatory Auto Repair Loans by TAB Bank and EasyPay Finance

May 11, 2022

Predatory Puppy Loans by TAB Bank and EasyPay Finance

February 1, 2022

Issue Briefs

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High-Cost Rent-a-Bank Loan Watch List

February 26, 2026

Predatory Rent-a-Bank Schemes are Evading State Law Across the Country; Congress Must Repeal the OCC’s Fake Lender Rule

May 12, 2021

Who Supports Overturning the OCC’s “Fake Lender” Rule?

May 3, 2021

Overturn the OCC’s “Fake Lender” Predatory Lending Rule

March 15, 2021

2021 Banking Agency Predatory Lending and Safe Banking Priorities

January 1, 2021

Payday Lenders Plan to Evade California’s New Interest Rate Cap Law Through Rent-A-Bank Schemes

October 1, 2019

Testimony

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Testimony Supporting Oregon HB 4116 Opting Out of DIDMCA

February 3, 2026

Testimony in Support of Rhode Island H 6055 on Interest and Usury

April 24, 2025

Testimony in Support of DC B25-0609 Protecting Affordable Loans Amendment Act

March 13, 2024

Testimony in Support of Maryland HB 254

January 23, 2024

Rent-a-Bank Schemes and New Debt Traps: Assessing Efforts to Evade State Consumer Protections and Interest Rate Cap

February 5, 2020

Press Releases & News

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New Predatory 100% APR Bank Seeks Trump Administration’s Approval

February 23, 2026

Appellate Court Upholds Colorado’s Power to Block Predatory Out-of-State Bank Loans

November 10, 2025

Advocates Urge Federal Appellate Court to Correct Reading of Federal Statute Permitting States to Reclaim Usury Authority

September 25, 2024

Senate Introduces 36% Rate Cap Bill to Curb High-Cost Loans, Junk Fees

December 15, 2023

2023 Update: Some States Tighten Rules Against High-Cost Installment Loans; Others Increase Interest Rates and Allow Junk Fees to Pile On

November 21, 2023

199% Auto Repair, Pet Loans Face Crackdown by DC, States

July 12, 2023

American Banker: Colorado’s new law on high-cost lending may be a model for other states

June 7, 2023

New Colorado Law a Model for Stopping Predatory Rent-a-Bank Lending

June 6, 2023

FDIC Should Downgrade Three Banks Engaged in Predatory “Rent-a-Bank” Lending

March 30, 2023

Consumer Resources

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Consumer Alert: Deceptive Auto Repair Financing Practices

May 10, 2022

How to Stop EasyPay Finance/TAB Bank Automatic Debits from Your Bank Account

May 10, 2022

Amicus Briefs

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Amicus Brief: NAIB v. Weiser (10 Circuit, DIDMCA opt out)

September 23, 2024

Opportunity Financial LLC v. the Department of Financial Protection and Innovation for the State of California

April 21, 2022

Amicus Brief Opposing Demurrer in OppFi v. DFPI

March 7, 2022

Amicus Brief in People of the State of California v. FDIC

April 29, 2021

Amicus Brief in People of California v. Office of the Comptroller of the Currency

December 17, 2020

Amicus Brief: Fulford v. Avant

January 13, 2020

Amicus Brief in Martha Fulford v. Marlette Funding

January 13, 2020

Legislation

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Testimony Supporting Oregon HB 4116 Opting Out of DIDMCA

February 3, 2026

Testimony in Support of DC B25-0609 Protecting Affordable Loans Amendment Act

March 13, 2024

Testimony in Support of Maryland HB 254

January 23, 2024

From the NCLC Digital Library

Consumer Credit Regulation

Innovative thinking and precise authority on predatory lending and other consumer credit, including the latest on rent-a-bank attempts to evade state usury laws, on the NCLC Digital Library.

Read Chapter One

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