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1 [1] (October 3, 2018)

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                                                                                                    October 3, 2018

Consumer Credit Markets and Loan Pricing: The Basics


Congress has demonstrated an ongoing interest in consumer
credit markets. This In-Focus provides an overview of
consumer lending markets, pricing, and legislative efforts
designed to facilitate efficient credit allocation and pricing.

Ccsw§ nmer KQredk Markets,
Credit allows consumers to make purchases today rather
than postpone them until some point in the future, thus
avoiding the need to save sufficient amounts of funds to
make payments in full. The consumer credit (loan) markets
consist of multiple products with numerous market prices.
Consumer credit may be in the form of mortgages,
revolving credit cards, automobile loans, personal loans,
and student loans. Consumers may obtain loans from
depository institutions (i.e., banks and credit unions) and
non-depository institutions (e.g., payday lenders, finance
companies). Lenders generally underwrite loans, meaning
that they evaluate loan applicants' credit risk by considering
factors such as their income and repayment histories of past
loans. (Some non-depository lenders, however, make
higher-priced consumer loans without formal underwriting.)

When a loan default occurs, the contract provisions
negotiated by the lender and a third-party loan servicer
(who collects payments from borrowers, administers
disbursements to the lender and, if necessary, to escrow
accounts, insurance providers, etc.), in conjunction with
relevant laws, determine (1) whether the servicer can offer
loss mitigation solutions and, if so, what types and with
what limitations; and (2) when the servicer can begin the
formal debt-collection process or initiate foreclosure and, if
so, any rules that must be followed and allowable actions.
Servicing rules are designed to minimize the costs to collect
defaulted obligations, which are primarily borne by the
lender. Lenders may attempt to recover debts by doing their
own collecting or by hiring contractors to collect the debt
on their behalf. The Fair Debt Collection Practices Act
(FDCPA) of 1977 prohibits debt collectors from using
abusive, unfair, or deceptive practice while collecting
consumer debts. If, however, a lender decides to sell the
debts outright, FDCPA may not apply to debt buyers.
Because resolving defaults can be expensive, these potential
costs are frequently priced into loans.


Lender profits are principally generated from the difference
between the loan price (interest rate charged to the
borrower) and the costs incurred by the lender to acquire
the funds that will be lent. A loan price may be separated
into two components: the risk-adjusted base rate and the
mark-up, discussed below.

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The determination of the price borrowers will pay for a loan
typically begins with the determination of the risk-free base


rate. Given that U.S. Treasuries have never defaulted (nor
do they prepay), Treasury yields or rates are considered
risk-free. Hence, the slope of the yield curve (shown in
Figure 1) consists of the rates of return that lenders could
receive by lending to the U.S. Treasury (i.e., purchasing
U.S. Treasury bonds) at different maturities. Lenders
require compensation from consumer loans to be at least as
high as the risk-free lending rate; otherwise, they would
simply purchase risk-free Treasuries. Consequently, the
base rates for loans are generally set to comparable yield
curve loan maturities. For example, the base rate of a 5-year
consumer loan is likely to begin with the current rate of a 5-
year U.S. Treasury rate. (The base rate for a 30-year
mortgage loan, however, may begin with the 10-year
Treasury rate because many mortgage loans are usually
repaid or refinanced in 10 years.)

Figure I. Upward-Sloping U.S. Treasury Yield Curve

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Next, the initial base rate is risk-adjusted to account for
financial risks that are idiosyncratic to borrowers. Risk-
based pricing is the practice of charging riskier borrowers
higher rates to reflect their additional default (credit) risk.
Higher-risk borrowers are likely to pay more for credit
relative to lower-risk borrowers, but risk-based pricing may
result in fewer credit denials and greater credit accessibility.
In short, borrowers pay different prices for credit products,
often because they pose varying levels of default risk.
Lenders may also factor in the prepayment risk of
borrowers, or the likelihood that a borrower pays off a loan
ahead of schedule when market interest rates change.


The markup above the risk-adjusted base rate consists of
additional charges and fees that are generally unrelated to
borrower financial risks.

*  Markups include loan origination costs, such as the costs
   to purchase credit reporting data and verify borrowers'
   identities, incomes, and employment.

*  Markups include ancillary costs, such as costs to cover
   loan servicing.


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