Product: Payday loan, title loan, personal loan, or advance loan

Dear CFPB Team, I am filing this complaint to bring to your attention the deceptive and predatory practices of Personify, a lender offering financial products that exploit consumers through exorbitant interest rates and potential violations of federal and state lending laws. 

Background and Specific Issues Personify offers loans with interest rates as high as 90 %, targeting financially vulnerable consumers who may be unaware of the true cost of these loans. These lending practices appear to : 1. Exceed Legal Interest Rate Limits : Many states impose usury laws or interest rate caps on loans, and the rates offered by Personify far exceed what is legally permissible under these laws. Additionally, under Section 85 of the National Bank Act, financial institutions must adhere to the default rate limits set by their respective states, and lenders can not circumvent these limits by exploiting grey areas of regulation. 


2. Operate in a Grey Business Area : Personify positions itself as a lender offering " alternative financial products, '' but its practices do not align with the legal and ethical standards required of financial institutions. By skirting the protections that licensed financial institutions must follow, they exploit regulatory gaps to charge excessive interest rates, a hallmark of predatory lending.

3. Engage in Predatory Lending Practices : Personify 's high-interest loans, coupled with deceptive marketing, target financially distressed consumers who may lack the knowledge or resources to fully understand the terms and consequences of the loans. This disproportionately impacts low-income individuals and traps them in cycles of debt. 



Legal Framework and Precedents Personifys practices raise significant concerns under several legal standards : The Truth in Lending Act ( TILA ) : Requires lenders to fully disclose loan terms, including the annual percentage rate ( APR ). If Personify fails to adequately explain its loan terms, it may be in violation of TILA.

Dodd-Frank Wall Street Reform and Consumer Protection Act : Prohibits unfair, deceptive, and abusive acts or practices ( UDAAP ) in the consumer financial marketplace. Personifys exorbitant rates and lack of transparency likely qualify as UDAAP violations. 

State Usury Laws : Many states have strict caps on interest rates, and loans exceeding these caps are often deemed illegal. 

Precedents in Predatory Lending Cases : Similar predatory practices have been successfully prosecuted and curtailed, as seen in cases involving payday lenders and high-interest installment loans. 


Consumer Impact Consumers, including myself, are often unaware of the deceptive practices and legal violations perpetrated by companies like Personify. Many of us are desperate for financial relief and fall prey to these unethical practices, only to find ourselves in worse financial positions due to exorbitant interest rates and fees.

Proposed Fair Solution I request the CFPB to : 1. Investigate Personifys lending practices to determine whether they are in violation of federal and state lending laws.

2. Mandate a full refund of excessive interest and fees charged to consumers. 


3. Require Personify to cease offering loans that exceed legal interest rate caps or violate consumer protection laws.

4. Enforce stricter oversight and regulation of alternative lenders operating in grey business areas. 



Conclusion Personifys predatory lending practices are not only unethical but likely illegal under federal and state laws. These practices exploit the financial vulnerabilities of consumers, perpetuating cycles of debt and financial distress. I urge the CFPB to take immediate action to protect consumers from further harm and ensure Personify is held accountable for its actions. 

Thank you for your time and attention to this matter. I am willing to provide any additional information or documentation necessary to support this complaint.