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Credit Cards Debt Financial Regulation

How the lessons of Tide Pods could clean up the credit card industry

While popular, Tide Pods are staggeringly dangerous for young children and people with disabilities.

Proctor and Gamble launched the Tide Pods in 2012.  In 2011, 2,862 children were hospitalized because of laundry-detergent related injuries. In 2013, that number was triple: 9,004 children were driven to hospitals by laundry detergent.  

The problem isn’t that Tide Pods are uniquely toxic, or contain chemicals never used before. The problem is that they’re cute. They’re colorful. And they’re small. It’s the good things about Tide Pods that we have to change to make them safer.  

What Tide Pods teach us about consumer product safety is that it’s not always the “bad parts” of products that make them risky: products aren’t always risky because of a gear that breaks and causes an accident, faulty wiring, or a toxic ingredient.  Tide Pods drove children to the hospital not because they had more bad parts than other detergents, it’s because they had more good parts: they looked better and felt better. A bill put forth in the New York State Assembly would force detergent packets sold to be in “opaque, uniform colors” — unlike the squishy, candy-like, blue-white-and-orange Tide Pods sold today. Seems like a good thing to me: changing the color scheme may make the product less popular, but won’t make the product any less effective.  

To help get Americans out of debt, regulators need to force banks to make their financial products less like squishy, colorful candy. We need ugly detergent that is just as good at cleaning clothes but poisons fewer children. We also need financial products that are equally good at helping families navigate a challenging economy but that tap into fewer of our weaknesses and biases.

Despite a handful of useful credit card regulations passed in 2009, too high of a percentage of Americans paychecks still get lost to loan interest and fees. While student loan debt dominates the news cycle, more American families hold credit card debt than any other form of loan: roughly half of all Americans carry an interest-bearing balance on credit cards.  Last year, Americans paid more than $104 billion in credit card fees and finance charges: an average of $823 per American family.  In the face of unstable and low-paying jobs, credit cards and other consumer lending products can sometimes help families plug goals and pay gaps, but clearly turning over $823 from American paychecks to big banks ultimately makes the problem worse.

Credit limit increases and credit card rewards are two “features” that make credit cards dangerous — and both “features” could be regulated in ways that wouldn’t make it harder for the Americans who actually face short term borrowing needs.

Banks should be required to get the customer’s permission before raising their credit limit. 

Imagine you’re on a diet and you’re trying hard to cut back on sweets. Many of us find it hard to turn down the plate of cookies sitting out in the break room, even if we’d be unlikely to go down the block to buy dessert. Similarly, for the many Americans struggling to make ends meet, a high credit limit is an unwanted invitation to take on debt they know will cause stress and heartache. Researchers Scott Schuh from the Federal Reserve Bank of Boston and Scott L. Fulford of Boston College found that for Americans who borrow money on their credit cards “nearly 100% of an increase in credit limits eventually becomes an increase in debts.”  There’s a huge psychological difference between applying for a new loan versus using credit that’s already available on a credit card you have. You might not apply for a new loan to go to your cousin’s wedding, even if you’d charge it to an existing card without knowing when you’ll pay it back. Moreover, too many consumers think of the credit limit as the amount banks think they can ‘safely afford’ to borrow. 

The U.S. regulatory framework says a high credit limit is a good thing, implying issuers shouldn’t need your permission to raise your credit limit, but a quick scan of Twitter reveals that many consumers feel different when they say things like: “Got an email that my credit limit has been raised and that is so dangerous how do I decline ”  If customers had to request credit limit increases they actually wanted, instead issuers raising customer credit limit without customers prior consent, a high unused credit line wouldn’t be looming over so many Americans heads as an unwanted temptation to enter a debt trap. Australia and the United Kingdom are both good case studies here. Australia prohibits banks from raising credit limits except at the customer’s request, and in the United Kingdom, banks can’t raise the credit limits of people who haven’t been able to repay their card balance in full at least once over the last year. 

Credit card rewards are another trojan horse. For some consumers of course, the airline miles or cash back is huge boon — there’s no doubt that for Americans who pay their bill in full every month, getting 1% or 2% back on purchases is a nice perk. But Schuh has shown that to cover the cost of these rewards, banks have to charge high “interchange” fees to merchants, which in turn result in higher prices for consumers. Perhaps more importantly, credit card rewards make it even more tempting for people to spend money they don’t have. The European Union and Australia have both capped these credit card processing fees charged to merchants, which effectively eliminated rewards credit cards in those countries. And good riddance. Simpler products with fewer distinct terms make it easier for people to select the lowest cost option: consumers would find it easier to identify the lower-interest-rate cards if they weren’t also benchmarking the value of airline miles. And there’s no reason low-income Americans who don’t qualify for credit cards to begin with should pay higher prices at merchants to allow wealthy Americans with Chase Sapphire Reserve cards can fly first class to Japan. 

While payday lenders charge exorbitant rates and fees, the one thing you can say in defense of payday loans is that they are typically used by people who are explicitly conscious of the fact they’re borrowing money, and are aware it’s not going to be cheap. By contrast, credit cards are slippery, intractable instruments in a country where only 38% of jobs pay enough for people to afford a middle class life, and living within your means can be a constant struggle. Occasionally borrowing on a credit card is the right answer for a family: economists Kyle Herkenhoff and Gordon Phillips have found that unemployed Americans with more credit card liquidity are able to extend their job searches by putting bills on their credit card, ending up with higher paying jobs as a result. But many Americans come to find that despite their irregular income or unexpected expenses, using a credit card to smooth things over just makes their budget shortfalls more and more severe as time passes. Ending unsolicited credit limit increases and taking steps to curb credit card rewards wouldn’t limit Americans from accessing credit when they need it — unlike capping credit card interest rates, as Bernie Sanders and Alexandria Ocasio-Cortez have proposed, which would undoubtedly increase how many Americans get declined when they apply for new credit.

 By going after some of the seemingly attractive features of credit cards, we can make them less like multicolored detergent pods, and stop the banks from taking Americans to the cleaners. 

Categories
Financial Regulation

Cryptocurrencies are pointless. You should pay attention to them anyway.

I have never been hyped up about Bitcoin, the “blockchain,” or cryptocurrencies.

The basic premise behind Bitcoin is that it’s a currency you can send anywhere nearly instantly. The computing power of the millions of bitcoin “miners” is used to solve math problems which create a secure record of every Bitcoin transaction – that record of transactions is called the “ledger.” The miners get paid for keeping the system running by receiving a share of the small amount of new Bitcoins that are being continuously released. Anyone can see the code, and everything is “decentralized” — instead of a single central bank or government holding the power, lots of people participate and everyone can ‘verify’ each other, which makes it a “trustless system.” In theory, you can count on things working without putting faith in the other players. Other “cryptocurrencies” generally share important parts of that architecture – especially the decentralized record-keeping called the “blockchain.”

Now, it’s clear that in places where the local currency has completely broken down, it’s clear that Bitcoin can be really useful.

Venezuela has been struggling with chronic food shortages. President Nicolas Maduro’s government won’t let its citizens exchange bolivars into foreign currencies at a price that any international exporters will accept, making incredibly difficult to import food into Venezuela. Malnutrition is skyrocketing, and estimates suggest that infant mortality has increased more than 100-fold since their economic and currency crisis started. Jim Epstein has reported that many members of what used to be Venezuela’s middle class and upper classes have stopped other work to mine Bitcoin. Former doctors, lawyers, and engineers use Bitcoin to buy Amazon giftcards, and then use the Amazon giftcards to buy food which gets shipped to Miami, and then sent to Venezuela at a hefty fee. Yeesh.

In most of the world though, including in most of the developing world, if you have money to spend, moving your money where it needs to go isn’t a big problem. Remittances–sending money between countries–can still be costly, but for “low-tech” reasons that Bitcoin isn’t really able to solve.

There just aren’t that many reasons why people in the United States who aren’t trying to commit crimes or buy banned goods would find Bitcoin useful, and while it is kind of fashionable today to express the opinion “oh, I think ‘the blockchain’ is very promising even though I’m not a believer in cryptocurrencies,” personally I’m not even that optimistic about what blockchain technology will accomplish for the reasons explained by Kai Stinchcombe here.

Once I learned enough to feel like I understood the basics, I started mostly tuning out cryptocurrency news.

My general assumption was that if Bitcoin, Ethereum, or other smaller ‘coins’ either fizzle out or simply fail to ‘take off,’ it would be a big bummer for the people who invested heavily, but that life would continue on as normal the rest of us.

After a great conversation about this topic with a mentor in Durham (Check out his paper on CTFC regulation of bitcoin derivatives), I’m starting to think differently on why cryptocurrencies could end up mattering a lot, even if they aren’t “successful.”

Things often grow from small and “addressable” to big and scary without making a lot of noise along the way

Of course, Bitcoin, Ethereium and other coins have already seen both massive ups and downs in their prices. Early this year, Bitcoin’s price fell by 60% without causing any obvious problems majority of people who don’t own cryptocurrencies. We can’t take that to mean though that contagion wouldn’t spread in future crashes.

Today, cryptoassets represent a relatively small part of the economy, and an especially small amount of what is held by important institutions like governments, retirement plans, or deposit-holding banks. Imagine cryptoassets as the sapling of a plant that would be comparatively easy to rip out of the ground now – a plant that could blossom into something a beautiful flower, intractable kudzu, or nothing at all. It’s tempting to wait to and see what happens – but by the time the trajectory is obvious, it may be too late to forestall big problems.

Importantly, derivatives allow the amount of exposure held in the economy related to a particular asset to grow far beyond the size of the underlying asset class. I might have one mortgage, but in theory, an infinite number of people can place bets on whether or not I’ll repay my mortgage. Similarly, there might be $X in bitcoin in circulation, but there can be 10 times that amount in outstanding ‘bets’ on whether bitcoin’s price will go up or down.

The ideal time to place regulations on mortgage-backed securities wasn’t in 2009 in the midst of the crisis, or even in 2006 just before the crisis started, but probably a decade or more before as the asset class was growing and evolving.

What do we do?

Push back on government entities holding cryptocurrencies or associated derivatives:

Voters and citizens should be concerned with the investments held by the cities, states, and countries where they live. For most of us in the United States, the most important government investments are the pension funds of our state governments. In many parts of the country, including my home state of North Carolina, pension funds are managed by an elected State Treasurer. When state pension funds struggle, either former public servants get short-changed, or ordinary taxpayers are suddenly on the hook to fund the promises made. State pension funds can be tempted into ‘novel’ investments, especially if they’re worried about making ends meet down the road – but voters should push back on government entities holding cryptocurrencies or associated derivatives.

There are huge, important differences between investing in a stock and investing in a currency. If you bought 100% of the stock of a company, you would then own that company – you would then get to keep all of the profits from that company’s activities, and you’d also own any of that company’s assets.

If you bought 100% of a currency, that currency wouldn’t be very useful anymore.

Stocks are productive assets – on average, while some companies will fail, companies on average grow and become more valuable over time, which makes the underlying stocks more valuable over time for “good reasons.” Currencies on average do not become more valuable over time – unlike the stock market where most people can be “winners,” investing in currencies almost always zero-sum game where you’re betting on one currency becoming more valuable in relation to another currency. Investing in stocks or bonds lets you direct money to governments or businesses that need funding to do research or build things like roads or factories – but when money is sitting in currencies, it really isn’t “doing’ anything. You could say that investing is putting your money into places where adding money is likely to create growth, while speculating is finding someone who will take the opposite side of a bet with you that something is going to grow or change on its own. We often need our governments to invest on our behalf – but we should ask them not to speculate on our behalf.

Some entities have great reasons to buy currencies or associated derivatives. If you are a manufacturer that buys raw materials in the United States, manufactures something in Mexico, and then sells it to a European market, a big swing in the exchange rate between dollars, pesos, or euros could really put a wrench in your business, so you may want to ‘stockpile’ some of the currencies, or buy “derivatives” that let you lock in a future exchange rate. While an importer or exporter might want to buy foreign currency or foreign exchange derivatives to manage their exchange rate risk, there’s really no good reason for a state pension fund to do so — and there’s not an obvious reason why anyone needs to be betting on the relative positions of dollars and cryptocurrencies.

This general point of view was expressed by the head of the California State Teacher’s Retirement System, the nation’s second-largest public pension fund when a spokesperson told CNBC: “CalSTRS has not considered investing in bitcoin or cryptocurrencies in general […] We consider them the ultimate intangible and, at least right now, there’s no value behind them other than what other people will pay.” But CNBC reported in the same article that other institutional investors may be “on the fence.”

Reconsider how we regulate crypto-assets

There are a lot of variations of what this could look like.

Regulation can prevent or discourage some investors from holding cryptoassets. As an example, the fact the Security and Exchange Commission hasn’t approved any cryptocurrency “exchange traded funds” (ETFs) doesn’t prohibit investors from holding cryptoassets, but creates a hurdle that makes it less likely that institutional investors will choose to do so.

It may similarly make sense for Congress to pass legislation on the presence of cryptocurrencies or related assets in retirement plans – both pensions and 401(k)s – either through a cap on the percentage of of a retiree’s investments that can be held in cryptoassets, or an outright prohibition on the presence of these assets in retirement plans. Conceptually, this isn’t so different from the Employee Retirement Income Security Act of 1974, which prevented companies from putting more than 10% of a pension plan’s holdings in the company’s own stock.

Of course, it is completely possible that cryptocurrencies have a bright future, that they transform how ordinary people make payments and that they’ll become genuinely useful. My real point is that being a pessimist about cryptocurrencies is not a good reason to tune them out entirely.

 

Categories
Banking Credit Cards

“I’m not falling for your tricks” and other mixed reactions to credit limit increases

All it takes is a quick search on Twitter to see that credit limit increases drive incredibly strong and oftentimes mixed emotional reactions for Americans. To clarify, when I say ‘credit limit increase’ here, I’m talking about when a credit card issuer raises the limit of how much a customer is able to spend or borrow.

In theory, having access to more credit — that you’re under no obligation to use — seems like it would be a strictly good thing. It’s there if you need it, and if you don’t use your higher credit limit, your credit score will typically go up (this article explains why).

But clearly, many American consumers feel differently.

I looked at tweets that mentioned ‘credit limit’ and a major credit card issuer (I used Discover, Capital One, Chase, Citi, Bank of America and Wells Fargo).

Here’s what I learned:

Obviously a lot of people are happy when they get a credit limit increase

And some consumers think of a high credit limit as a sign the bank trusts and values them as a customer

But many Americans are afraid that having more credit available to them will lead them to take on more debt

And a lot of people self-identify as “not being ready” to use credit wisely

Americans don’t perceive their banks have their best interests at heart

It’s usually not clear or straightforward to decline an unwanted credit limit increase

But lots of people want or need a higher credit limit, and don’t know how to get it

There can be a huge disconnect between how banks see credit limit increases and how customers see them

For many Americans, getting a credit limit increase is like someone bringing you a plate of cookies if you’re on a diet.   Banks can reason ‘I’m doing this customer a favor — all they have to do is not eat the cookies if they don’t want the cookies.’    A common line of reasoning also says ‘most of the time, when I give customers the cookies they eat them, which must mean they want me to give them even more cookies.’

But we all know that self-control and will-power are limited resources.

For analysts and managers at banks, salaries tend to be high enough that it may be almost effortless for those people to ‘stick to their budget’ — but for most Americans, living within their means takes discipline and resourcefulness.

The less money you have, the harder it becomes to always ‘do the right thing.’  This is how the American Psychological Association describes the problem:

People at the low end of the socioeconomic spectrum may be particularly vulnerable to a breakdown of their willpower resources. It’s not that the poor have less willpower than the rich, rather, for people living in poverty, every decision — even whether to buy soap — requires self-control and dips into their limited willpower pool.

Taking a human-centric approach means that banks need to step away from the mentality of “this is in the customer’s rational best interest,” and meet customers where they are in life.

So what do we do about the problem?  

On the regulatory side, Australia previously had a law stating that banks needed to let customers accept or reject credit limit increases, rather than increase them without customer consent.  They recently revised that law to prevent banks from advertising credit limit increases altogether.  The latter  provision will almost certainly have some unintended consequences — if banks can’t raise credit limits after account opening, they’ll be incentivized to start customers at high credit limits to begin with, making them more likely to give a high initial credit limit to someone who really can’t afford it.  The earlier law though, which gave customers the right to accept or decline a higher credit limit, has some obvious benefits — it gives consumers more choice and autonomy to chart their financial future.

Angelia Littwin of Harvard University though has pointed out that since most banks choose to authorize some transactions that take a customer over their credit limit, credit limits aren’t really effective as a budgeting mechanism for consumers.

Ultimately, consumers need access to better tools to help them limit their spending to an amount they feel comfortable with.