It took two years, a lawsuit and a ruling from a federal judge, but Judicial Watch finally got hold of a batch of documents from the Federal Deposit Insurance Corporation (FDIC) related to the Citigroup and Bank of America bailouts. (The FOIA lawsuit, you may recall, was filed on behalf of former Federal Reserve and FDIC employee Vern McKinley.)

Specifically, we received the unredacted minutes from FDIC Board meetings during which FDIC officials and staff discussed the rationale for the bailouts which centered on the “systemic risk” of allowing the two financial institutions to fail.

We also received never-before-seen documents regarding the FDIC’s Temporary Liquidity Guarantee Program, which guaranteed unsecured debt of private financial institutions and provided them “full coverage of non-interest bearing [sic] deposit transaction accounts, regardless of dollar amount.”

Here are the highlights:

• FDIC Board Meeting Minutes from approval of Citigroup bailout (November 23, 2008):According to the minutes from the meeting, government officials described in vague terms the consequences of allowing Citigroup to fail, including “the effects on money market liquidity could be expected on a global basis,” “term funding markets remain under considerable stress” and the fact that it would “significantly undermine business and household confidence.” One FDIC Board member who was in attendance, John Reich, cautioned Federal bank regulators and the Treasury Department to “avoid ‘selective creativity’ in determining what constitutes systemic risk and what does not and what is possible for the government to do and what is not.”
• FDIC Board Meeting Minutes from approval of Bank of America bailout (January 15, 2009):According to the meeting minutes, Sheila Bair, Chairman of the Board of the FDIC, admitted the agency “was relying on data analysis by the Federal Reserve” and for that reason the FDIC “very much needs to proceed with a systemic risk determination with respect to [Bank of America].” Chairman Bair characterized the decision to bail out Bank of America as demonstrating that the FDIC, an independent agency, was a “team player along with the Federal Reserve and the Treasury to prove the systemic risk case.” (Translation: Treasury and the Fed really want this so we have no choice but to go along.)

Incidentally, these meeting minutes are consistent with a separate report by the Special Inspector General for the Troubled Asset Relief Program released on January 13, 2011.

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Prepare to be outraged.

When government officials pitched the Fannie Mae and Freddie Mac “bailouts” to the American people, we were told the purpose of this “taxpayer investment” was to bring solvency to two institutions that were simply “too big to fail.”

Nobody ever said anything about forcing the taxpayers to pay the legal bills of the political Fannie and Freddie executives who were key to creating the housing crisis. But that’s exactly what’s happening.

The New York Times broke the story:

Since the government took over Fannie Mae and Freddie Mac, taxpayers have spent more than $160 million defending the mortgage finance companies and their former top executives in civil lawsuits accusing them of fraud. The cost was a closely guarded secret until last week, when the companies and their regulator produced an accounting at the request of Congress.

The bulk of those expenditures — $132 million — went to defend Fannie Mae and its officials in various securities suits and government investigations into accounting irregularities that occurred years before the subprime lending crisis erupted. The legal payments show no sign of abating.

One of the crooked executives specifically referenced by the Times is none other than Franklin Raines, Bill Clinton’s former budget director, who took a job as Chairman and Chief Executive Officer of Fannie Mae from 1999 to 2004. Raines allegedly cooked the books at Fannie, issued countless dubious mortgages, and then took a huge bonus before leaving the company. He is one of three executives who divvied up a tidy $24.2 million from the taxpayers to defend themselves in court.

Raines’ tenure at Fannie Mae was marked by massive corruption and mismanagement. And we’re supposed to bail him out, too? Once again the taxpayers are thrust into an Alice in Wonderland world where the government uses tax dollars to help politicians defend against government investigations.

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On December 23, the United States District Court for the District of Columbia denied a motion by the Federal Deposit Insurance Company (FDIC) to dismiss a Judicial Watch FOIA lawsuit filed on behalf of our client, former FDIC employee Vern McKinley.

Actually, U.S. District Court Judge Emmett G. Sullivan did more than deny the motion to dismiss.  He also granted, in part, Judicial Watch’s motion for summary judgment and criticized the FDIC by saying the agency “has not fulfilled its obligations under FOIA.”  Now the FDIC must conduct a new search for responsive records and demonstrate that the records have been provided or properly withheld under FOIA law.

This lawsuit, filed on March 15, 2010, is one of several we’ve filed on behalf of Mr. McKinley.  (You can find them all here.)  And all of these lawsuits have a similar purpose:  to determine under what legal authorities and lawful rationales the federal government initiated these massive financial bailouts.

In this case we’re seeking records related to the FDIC’s decision to guarantee $306 billion of loans and securities held by Citigroup, Inc., and $118 billion held by Bank of America.  The lawsuit also seeks information about the Temporary Liquidity Guarantee Program (TLGP), the FDIC program that now guarantees $394 billion in bank deposits and debt.

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The document trail below reveals some extremely troubling questions for Representative Barney Frank. Is the GAO report cited below truly the first serious investigation of the mortgage meltdown? Did Congress or the Financial Services committee he chairs have access to mortgage meltdown information from other sources, especially with said GAO report already well on its way to completion?

Why was Barney Frank pushing for his “expanding home ownership bill” in the midst of this looming crisis he already has good reason to suspect was going to get worse? Was he pushing it for purely political purposes prior to the 2008 election, while knowing full well the American housing market was headed for disaster and American taxpayers would be left on the hook as a result of his policies?

While not quite a smoking gun, an examination of the record suggests that while Rep. Barney Frank had good reason to be concerned of a pending meltdown in the housing sector, either out of sheer incompetence, or political maneuvering, he did the exact opposite of what he should have done as a representative of the people of Massachusetts.

Via Mortgage News Daily, on April 24, 2007, problems within the mortgage industry were already coming to light. And it was happening right in front of Barney Frank’s committee.

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Excerpted from Bought and Paid For: The Unholy Alliance Between Barack Obama and Wall Street. Published by Sentinel. Copyright Charles Gasparino, 2010.

But despite his trials, [Lloyd] Blankfein had taken time out of his grueling schedule to help a firm that wasn’t a Goldman client, not even a prospective one. The firm was ShoreBank Corporation, a small community bank located in Chicago that lent money to inner-city businesses and was exploring the possibility of financing nascent and as-yet-unprofitable “green” businesses through so-called conservation loans and environmental banking, according to the bank’s Web site.

The bank’s self-described mission was to “change the world.” And yet despite its seemingly good intentions, the bank’s urban commercial borrowers were suffering greatly from the lower property values and high unemployment that stemmed from post–financial crisis recession. Without Blankfein’s help (and the help of other
major Wall Street firms) ShoreBank would follow the fate of dozens of other banks during the great recession and face almost certain collapse and government liquidation.

To be sure, helping out a struggling bank that wasn’t even a client was a most un-Goldman-like thing to do. Goldman dealt with only the biggest companies in corporate America or with superwealthy individuals (typically, those with $10 million or more to invest with the firm). More thanthat, this was a firm that had a reputation for screwing just about any company, clients included, when business was on the line. Goldman, of course, would deny that assertion. Even so, in the normal course of business, a bank like ShoreBank, with its modest funds and do-gooder reputation, wouldn’t even appear on Goldman’s radar as a potential customer.

Yet for some seemingly inexplicable reason, Lloyd Blankfein—who had a net worth close to $500 million and until recently had never heard of ShoreBank—started imploring his friends at other firms, like Morgan Stanley, GE Capital, and others, to help this little bank. Not that Blankfein suggested there was money to be made here. Quite the contrary; it was simply the right thing to do.

To any casual observer, this puzzling scenario raises the question: Why would Blankfein possibly want to save ShoreBank?

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In the wake of recent reports that Shorebank’s financial status worsened in the second quarter, some interesting new developments have surfaced.

Yesterday afternoon, Fox Business News reported that Shorebank will now be the target of a federal investigation, to look into whether political pressure was exerted on Wall Street banks to give money to help the troubled Chicago community lending bank reach the monetary threshold needed to allow the bank to qualify for federal TARP funds.

Neil Barofsky, Special Inspector General for the Troubled Asset Relief Program (TARP), has said that he will begin looking into whether or not top-level political operatives (e.g., Eugene Ludwig, former comptroller of the currency under President Bill Clinton) and FDIC chief Sheila Bair were involved in exerting direct pressure to force Wall Street banks such as JP Morgan Chase, Goldman Sachs, and others to give money (which now totals more than $150 million) to the ailing bank.  Interestingly enough, Shorebank has been involved in raising private capital to qualify for TARP funds despite the fact that Shorebank senior vice president Michelle Collins emphatically stated just last year that Shorebank would take “no TARP money.”

Although the Obama administration has officially denied any involvement in helping to prop up Shorebank, the rush by other banks to come to its aid has been nothing short of remarkable.  More than a few eyebrows have been raised in response to the general flurry of activity shown by other, larger banks seeking to involve themselves in helping to rescue Shorebank.

For example, Lloyd Blankfein, Goldman Sach’s chief executive, was personally involved in making phone calls to encourage other Wall Street banks to inject capital into the the failing Shorebank.  This, in a stated effort to allow Goldman Sachs to fulfill its obligations under the 1977 Community Reinvestment Act.  (Interestingly, Ron Grzywinski, one of the founders of Shorebank, was the only banker to testify before Congress in favor of the Community Reinvestment Act.)

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The President is expected to sign the financial overhaul bill today, yet he might want to pause a moment to consider not signing this bill because of the potentially unconstitutional racial and gender preference provisions buried in the massive bill.

Four members of the U.S. Commission on Civil Rights have signed a letter complaining that Section 324 of the conference report titled the “Dodd-Frank Wall Street Reform and Consumer Protection Act” “includes a section on race and gender that even those who pride themselves on keeping up with national affairs may have failed to notice.” This provision, which can be found on page 172 of the conference report, may lead to unconstitutional racial and gender preferences being forced on financial institutions covered by the new law.

As the Becker-Posner blog argues, this over 2000-page long bill is “complex, disorderly, politically motivated, and not well thought out reaction to the financial crisis that erupted beginning with the panic of the fall of 2008.” One of the critiques leveled by Gary Becker and Richard Posner is that “the bill adds regulations and rules about many activities that had little or nothing to do with the crisis.” It is clear that the lack of racial and gender preferences had nothing to do with the financial meltdown in the fall of 2008. Section 342 is a special interest provision that has no relevance to financial services reform and may lead to this law being deemed unconstitutional by the courts.

The letter from members of the U.S. Commission on Civil Rights was signed by Commissioners Peter Kirsanow, Ashley Taylor, Gail Heriot, and Todd Gaziano. In the letter these experts in civil rights law explain that the legislation “requires that each covered agency establish an ‘Office of Minority and Women Inclusion’ responsible for ‘all matters of the agency relating to diversity in management, employment, and business activities.’” This law will empower federal bureaucrats to issue rules and regulations governing the financial sector of the economy, if those businesses are doing any work for the federal government.

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On April 22nd we published an article entitled IndyMac Attack: Did Schumer, Paulson, Soros, and the CRL Kill the Bank and Profit From Its Collapse? We summarized the story as follows:

At the end of 2007, hedge fund billionaire John Paulson invested $15 million in the leftist non-profit, Center for Responsible Lending, their largest single donation ever. Around the same time, Paulson and his employees contributed over $100,000 to the Democratic Senatorial Campaign Committee, headed, at the time, by Sen. Chuck Schumer. Roughly six months later, CRL and Sen. Schumer both launched a highly public attack on the California-based mortgage lender, Indymac. The lender failed, wiping out the investment of thousands of people. Roughly six months after that, John Paulson, in partnership with George Soros, bought up the remnants of Indymac for pennies on the dollar.

…a top executive of CRL when this deal went down, Eric Stein, is now working at the Treasury Department, heading up the proposed Consumer Financial Protection Agency. Mr. Stein will be the chief federal official designing regulations to protect consumers. Right.

At the time, we asked if this could all be coincidence.  Today, we are getting closer to answering this question.

As reported by hedge fund blog AbsoluteReturn+Alpha, Congressman Darrell Issa (R-CA), ranking member of the House Committee on Oversight and Government Reform is probing John Paulson on his relationship with the Center for Responsible Lending.

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The Central Illinois 9/12 Project became one of the first to expose — beginning this past March on BigGovernment.com – Shorebank’s extensive green and microfinancing agendas, in anticipation of that bank’s impending bailout.  Shorebank, a Chicago-based, community-based investment bank, is focused on domestic and foreign microfinancing, is heavily engaged in the financing of “green” projects and “green” jobs, and has a host of ties to the Obama and Clinton administrations.  Most recently, we wrote in April about Shorebank seeking a “bailout” from larger financial firms that have previously received bailout money from the federal government. Congresswoman Jan Schakowsky had previously proposed that the bank receive funds from the State of Illinois to help cover its loss of capital since the beginning of the nation’s economic downturn in 2008.

As we previously wrote, Shorebank would potentially be eligible for TARP funds if it were to be recognized as a “Community Development Financial Institution.” In order to to received needed federal TARP money and prevent seizure by the FDIC, Shorebank needed to receive appropriate matching funds from private sources.  News stories have been released over the past several days indicating that Shorebank has potentially received such funding.

Shorebank has reportedly received $20 million from General Electric, $20 million from Goldman Sachs, and $20 million from Citigroup – with additional large funds being promised by J.P.Morgan Chase, Bank of America, and Morgan Stanley. Shorebank also has received funds from the Northern Trust Corporation, State Farm, and Harris N.A.  It has been reported that the bank could also receive funds from Wells-Fargo and PNC Financial Services.  Assistance from these financial institutions puts Shorebank’s raised capital from private sources within the range needed to make it eligible for TARP funds.

As we reported previously, Citigroup, Bank of America, and Chase all received tens of billions of dollars in taxpayer money from TARP.  Does this then mean that Shorebank is being bailed out by bailout money?

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By now, readers of BigGovernment.com know that that the Democrats “Wall Street Bank” bill, which may get a final vote as early as this week, will reach far beyond Wall Street and ensnare businesses not typically thought of as “banks.” Stories here by this author and others have laid bare provisions of the Obama-Dodd-Frank-Everything’s-A-Bank bill that broadly define a “financial company” as any business “substantially engaged” or “significantly engaged”  in financial activities. And if your business happens to fall in such a category, it could be subject to a bailout “assessment” tax to bail out a high rolling financial firm, intrusive regulation by a banking agency or the new Bureau of Consumer Financial Protection, or even outright nationalization if the troika of the Federal Reserve, Treasury Secretary, and Federal Deposit Insurance Corporation decide your firm is a threat to “financial stability.”

Trouble is, though its audience is growing by leaps and bounds every day, this site is still at the point in which not every American relies on it for essential political info. And because Republicans have done a mediocre job of explaining how far this bill would reach, and the establishment media largely has no interest in explaining these facts, supporters of Senate Banking Committee Chairman Chris Dodd’s “Restoring American Financial Stability Act” have been able to get away with saying, “If you’re against this bill, you’re against reform of Wall Street.”

Or at least, that was the case until a couple days ago. That’s when Sen. David Vitter (R-La.) introduced an amendment with a straightforward message: A bill that claims to be about fostering transparency on Wall Street should itself be transparent in its objective and not sneak regulation on Main Street manufacturers and retailers.  Call it (and I just did) the Not-Everything’s-A-Bank Amendment.

Vitter has distinguished himself with his dedicated efforts in fighting for real financial reform.  He co-sponsored with self-proclaimed (but not necessarily sole) Senate socialist Bernie Sanders (I-Vt.)a bipartisan amendment similar to the measure in the House bill to have the Government Accountability Office audit the Federal Reserve. When Sanders and others went for the Obama administration”compromise” of a one-time audit of a limited part of the Fed’s operation, Vitter carried the flag of Fed transparency.

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Health care reform is the latest piece of the puzzle to be put in place. If you add this to what has happened in the financial industry and the banking industry a bigger picture begins to emerge. With the proposed financial regulations, there seems to be a movement towards the consolidation of power in a few institutions, systematically removing free competition, setting up the too big to fail phenomenon, thereby giving people less choice that will ultimately cost everybody more in the long run.

Since the passage of healthcare reform, there has not been a lot of talk about the role that hospitals will play. What no one talks about is the fact that there has been a quiet movement or shift of doctors from private practice to hospital employees. Many smaller community hospitals and doctor owned hospitals have gone out of business because they could not afford to keep their doors open. In addition, there has also been a quiet consolidation of hospitals. For example, in Atlanta, groups of specialists have become hospital employees.  With the movement of various specialists, hospitals have now become specialty centers for specific patient care.

It is not hard to visualize a future where there will only be a certain number of hospitals that are able to provide care for specialized diseases such as cardiac care, or orthopedic surgery.  If that happens, access will be restricted since patients will be limited as to where they will be able to go to receive their care.  If there was only one specialty heart center in the city and only a certain number of doctors on staff, by definition, there will be a limited number of patients that can be treated at any specific time. Unfortunately, these changes will likely lead to the de facto rationing of care.  In addition to the problem of access, costs will likely go up because of the lack of competition.

The demise of Lehman Brothers and the consolidation of other large financial companies have led to very few winners in the financial industry – the biggest of which is Goldman Sachs.  The banking industry has seen a few surviving large institutions such as Chase and Citibank. What the larger banks didn’t acquire in mergers, the FDIC removed by taking over and closing hundreds of smaller and community banks. Makes you wonder if the credit unions will be next on the list.

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There are many bad things contained in Chris Dodd’s Restoring American Financial Stability Act,” the financial regulatory “reform” bill that after filibustering for three days — with the assistance of Nebraska Democrat Ben Nelson — Republicans agreed to let come to the floor for amendment and debate.

Among its horrors are a massive new consumer agency with the power to track virtually every financial transaction to share with other big agencies like the IRS, onerous new restrictions on angel investors and venture capital that greatly delay funding promising startup firms, proxy access provisions that would federalize state incorporation laws and empower unions and other progressive shareholders to wage director campaigns at the company and other shareholders’ expense, and no attempted reform of the government-sponsored enterprises Fannie Mae and Freddie Mac at the center of the financial mess.

But the most destructive portions of the bill — the one that would in my judgment go beyond even Obamacare in making the American free enterprise system unrecognizable — has been little discussed even by critics of this bill. To put it bluntly but absolutely accurately, this bill sets up a mechanism for the Treasury Secretary, the Federal Reserve, and the Federal Deposit Insurance Corporation to nationalize virtually any business they deem to be a threat to American “financial stability.”

I include myself among these critics not focusing on this issue and I apologize for not informing readers sooner, but I wanted to be sure the bill would do what I suspected it would do. Many of the bill provisions are interconnected, and what can seem like a mild measure by itself becomes lethal when combined with another sections. As Financial Times columnist Gillian Tett recently wrote: “Buried in [the bill’s] pages are numerous clauses and sub-clauses, many of which have been largely ignored until now (partly because they strike most non-financiers as pretty dull). Yet, the fine print could turn out to be crucial in the coming years.”

And after reading and rereading the “fine print” of this 1336-page piece of legislation (which will grow by hundreds more pages when amendments are added), it is clear that the bill’s “orderly liquidation authority” would facilitate outright government seizure of a wide variety of firms with very limited judicial review.

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Sen. Chris Dodd’s financial regulatory reform bill, on which the Senate is slated to take a cloture vote this afternoon, has been the subject of much criticism of late, primarily for what opponents say amounts to a de facto institutionalization of “too big to fail” with regard to the biggest power players in the financial sector.

However, Capitol Confidential has learned that there is another, equally troubling aspect of the bill that observers say is going unnoticed in the debate surrounding Dodd’s proposals: Its hammering of community banks.  Relatively small institutions compared to the names often cited in the news, community banks typically operate in small towns, urban neighborhoods or the suburbs.  Their remit usually involves funding small businesses that require credit in order to operate payrolls and to expand, and lending to families financing home purchases or college.   Many of those familiar with the banking industry, overall, say that community banks bore little to no responsibility, on balance, for the financial meltdown that occurred in 2008.  Nonetheless, an analysis of the Dodd bill indicates that if it passes, community banks will be subject to a whopping 27 new regulations that one individual who has worked with banks professionally and is closely tracking the legislation says “could threaten to put many community bankers out of business, thus reducing competition in the banking sector overall, and diminishing consumer choices.”

That individual further asserts that while the bigger, Wall Street banks will likely be able to adapt to the bill (though their efficiency and ability to compete internationally could take a knock), the community banks will not—potentially making the system more risk-prone, also.

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From the Associated Press:

Regulators shut down the bank owned by Illinois Treasurer Alexi Giannoulias’ family on Friday, setting up an expected but daunting challenge in his bid to keep President Barack Obama’s old Senate seat in Democratic hands.

Broadway Bank, which was heavy into real estate loans and lost $75 million last year, had been given until Monday to raise about $85 million in new capital, but the Federal Deposit Insurance Corp. announced at the close of business Friday that Broadway was among four banks, all in Illinois, that had failed.

Giannoulias, 34, worked at the bank as a senior loan officer until he ran for treasurer four years ago. He has tried to take some of the political and public relations sting out of a collapse, acknowledging the bank was likely to fail but blaming the bad economy. He also said it was financially healthy when he left four years ago.

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It’s not often the two Republican Senators from Maine safeguard the country from excessive government with more vigilance than a Republican Senator from Tennessee.  But on the issue of Financial Reform, Sen. Collins and Snowe have become champions for the taxpayers — holding the line against more bailouts and bureaucracy — while Sen. Bob Corker continues to push the country toward permanent bailouts and a Washington regulatory scheme “one like we have not seen before.”

Big Government readers are well aware of Corker’s repeated attempts to cut a deal with “Countrywide” Chris Dodd.  Despite signing a letter pledging to oppose the legislation, Corker is now taking to the airwaves denying the legislation contains a permanent bank bailout provision.

Neat trick Senator. Swear to your constituents that you oppose further bailouts and then push a bailout bill by simply saying it contains no bailouts.

Corker has become to Financial Reform what Sen. Lindsey Graham is to climate change legislation — a sucker.  And his words are being used by left-wing activists to deny there is a bailout in the legislation.

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Surprise, surprise. Sen. Chris Dodd’s financial-regulation proposal raises the possibility of substantial progress on the road to ending “too big to fail” (TBTF) and bailout nation for banks and other financial institutions.

How the Dodd bill will play out in the final details remains to be seen. But when you read the Dodd fact sheet, there are a few key items to like.

First, under the Dodd scheme, large complex companies will have to submit plans for rapid and orderly shutdowns should they go under. These are called “funeral plans.” Then, in terms of these orderly shutdowns, the bill would create an “orderly liquidation mechanism for the FDIC to unwind failing systemically significant financial companies. Shareholders and unsecured creditors will bear losses and management will be removed.” Good.

Then comes the “liquidation procedure.” This spells out that the Treasury, FDIC, and Federal Reserve must all agree to put companies into the orderly liquidation process. “A panel of three bankruptcy judges must convene and agree — within 24 hours — that a company is insolvent,” the bill goes on to say. It also states that the largest financial firms will be assessed $50 billion for an upfront fund that will be used if needed for any liquidation. This is a kind of debtor-in-possession safety net for the bankruptcy-liquidation process. Also good.

Finally, under the heading of bankruptcy, the bill stipulates that most large financial companies are expected to be resolved through the normal bankruptcy process. This is the key. However, it is not an airtight case for bankruptcy. It is possible that a government-resolution process could keep big banks alive or in conservatorship, such as with Fannie and Freddie. That would be wrong. Very wrong. In fact, one of the flaws in the Dodd bill is that there is no mention of Fannie and Freddie.

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More than three-quarters of the $2 billion in federal stimulus funds intended to create green-energy jobs in the U.S. has gone to foreign-owned companies

Despite millions in federal tax credits, wind-equipment manufacturers cut thousands of jobs in the U.S. last year

Las Vegas receives $4.5 million federal grant to build the neon museum

Alaska Senators fight to restore funding for earmark that both President Bush and Obama have tried to eliminate

New Jersey Senator prodded the Federal Reserve to aid a struggling bank whose chairman and vice chairman were big campaign contributors

Media critics agree the U.S. Census Bureau’s $2.5 million Super Bowl ad was one of the worst

$501,940 of federal stimulus aid will help finance an animal shelter, which will include pet bathing areas and a kitten nursery

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In 2007, the FDIC set up an ill-conceived program for 30 banks to offer short-term loans of up to $1,000, at a maximum APR of 36%.  They thought this “Affordable and Responsible Consumer Credit” program would prove that lenders could make a profit under these conditions while still serving the consumer’s needs.

The results are akin to the hapless ski jumper at the opening of Wide World of Sports, who slips, falls, flails, smashes through a banner, and lands with a resounding thud on the landing pad.

While payday loans are approved in a mere 15 minutes, most of these FDIC-sponsored loans took more than 24 hours to approve — failing consumers who needed their funds immediately; some required direct deposit, credit checks and possibly a financial literacy class or collateral (none of which are required for a PDL); some required a portion of the loan be put on deposit (not part of the PDL process); only a few thousand loans were made because of said inconveniences (compared to 100 million loans annually for PDLs due to their convenience); and none of the institutions actually made a profit while some lost money, even when including an origination fee of up to $50 (whereas PDL’s profitability allows them to be widespread and easily accessible).

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