Small amount loan borrowers are not vulnerable, NCPA argues
The image of consumers using small amount credit contracts as mostly vulnerable Centrelink clients has been challenged by new research, which claims the majority of borrowers are employed.The National Credit Providers Association, which represents small amount lender, commissioned CoreData to survey the market for its submission to the Government's review of small amount credit contracts.According to the research, 988,000 consumers took out a total of 1.3 million loans worth A$667 million in the 2014/15 financial year. The average loan size was just over $500.The research included consumer loans of $5000 or less, although the vast majority were small amount credit contracts (loans up to $2000 with terms between 16 days and 12 months).This compares with 2013/14 figures, when 800,000 consumers took out 1.1 million loans worth $554 million.The average term in 2014/15 was 117 days. In the June quarter this year, 64.5 per cent of borrowers were employed.The Australian Securities and Investments Commission's estimate is that the industry provided around 1.5 million loans worth more than $813 million in 2014/15. It put the average term of a loan at 50 days.The CoreData research also challenges the idea that small amount loans give rise to a large number of complaints. CoreData reported that five in 10,000 consumers make contact through a consumer advocate each quarter with an issue about a loan.Another theme coming out of the research is that small amount lenders are not usurers. Since interest rate and fee caps were introduced in 2013 the industry has been marginally profitable, with rising costs of compliance not matched by revenue growth.According to the NCPA, there has been a steady exodus of small participants from the industry over the past few years.The submission argues that more regulation will only mean that people who need access to small amount loans will find them harder to get.The NCPA said the Government should consider putting some of the regulatory burden on consumers. "There is nothing in the legislation which creates any obligation on borrowers," it said."Lenders see many occasions in which borrowers create circumstances under which lenders simply are unable to discover matters which should be available to them in order to comply with their responsible lending obligations."The association recommended that the need for warning statements be reconsidered (ASIC's submission called for them to be more prominent), and that loan forms be amended to "reduce the strong focus on the availability of external dispute resolution schemes and the 1800 counselling phone number."The association also called for credit repair companies and financial counsellors to be licensed.