Consumer complaint received 2026-01-02 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Title loan
Issue: Charged fees or interest you didn't expect — 
Company: WHEELS FINANCIAL GROUP, LLC.
State: LA

Complaint narrative:
In the letter, we document numerous complaints about installment loans up to 180 % APR made by the following XXXX XXXX  lending partners : XXXX XXXX, which operates the auto title lender XXXX, using the XXXX brand for its XXXX  loans at rates up to 178 % XXXX and potentially higher XXXX XXXX XXXX XXXX which operates the payday lender XXXX XXXX XXXX and offers XXXXXXXX online installment loans through the XXXX XXXX at rates up to 225 % APR XXXX XXXX which offers XXXXXXXX installment loans online in certain states through bank partners, including XXXX XXXX at rates up to 149 % APR XXXX XXXX ( XXXX ), which offers online installment loans at 160 % APR Several small predatory lenders, including : o XXXX XXXX XXXX dba XXXX XXXX, which offers online installment loans up to {$3000.00} at up to 224 % APR 2 o Lendly, which offers installment loans up to {$2000.00} with a typical 199 % APR for loans repaid by payroll deduction and 225 % APR otherwise o XXXX, which offers the XXXX XXXX  Flow line of credit . The website does not disclose an APR but the pricing show has an effective APR of about?? 
o XXXX XXXX, dba XXXX XXXX, which offers online installment loans up to {$3000.00}. The rates are unclear. 
o XXXX XXXX XXXX which offers online installment loans up to {$3000.00}. The rates are unclear. 
Those nonbank lenders launder their loans through XXXXXXXX XXXX ( and other Utah banks ) in order to attempt to evade state interest rate laws that forbid loans at such predatory rates. 
These XXXX XXXX partners have been the subject of extensive complaints, as well as enforcement actions and private lawsuits. Collectively, the complaints against the loans enabled by the bank reveal : Lack of transparency around high interest rates Unaffordable loans that borrowers are unable to repay Receiving loans that they never applied for and identity theft Improper debt collection tactics, including collecting debt not owed, failure to validate debts, harassment and abuse Credit reporting problems, including incorrect information and failure to respond to disputes and errorsUnfair, deceptive, abusive or unconscionable practices. The complaints show lack of transparency around high interest rates, and unfair, abusive and unconscionable lending practices due to unaffordable loans that consumers struggle to repay. State UDAP laws and laws against unconscionability apply to state-chartered banks, especially banks like XXXX XXXX that do not have branches outside their home state.11 Debt collection practices. Many of the complaints are about debt collection. The Federal Debt Collection Practices Act ( FDCPA ) was enacted to protect consumers from unfair, abusive and deceptive practices by debt collectors. The FDCPA requires, among other things, that debt collectors refrain from harassing consumers, making inappropriate threats, or misrepresenting the alleged debts owed. Although the FDCPA does not apply to first-party creditors like banks or their servicers, such conduct also generally constitutes a violation of federal and state UDAP laws that do apply.12 Moreover, some state debt collection laws cover creditors and servicers,13 and debt collection laws are not generally preempted by federal banking regulations.14 Creditors can also be liable under state agency law for the actions of their collectors and servicers.15 Credit reporting. A large number of the complaints are about credit reporting. When creditors report information to credit bureaus ( directly or through servicers ), the Fair Credit Reporting Act ( FCRA ) imposes requirements on furnishers to provide accurate information, to respond to consumer disputes, to conduct reasonable investigations, and to promptly correct inaccurate information.16 Know Your Customer and Electronic Signature Laws. Many of the CFPB complaints are about 11 State UDAP laws and laws against unconscionability apply to state-chartered banks, especially banks like XXXX XXXX that do not have branches outside their home state. While state-chartered banks are entitled to the same interest rate exportation rights as national banks, they do not have the same broad preemption rights with respect to other laws except when they are operating out of an out-of-state branch. The FDIC has explained that the preemption provided by section [ 12 U.S.C. 1831a ( j ) ] only operates with respect to a branch in the host state of an out-of-state, state bank. By its terms section [ 12 U.S.C. 1831a ( j ) ( 1 ) ] would not apply if the out-of-state, state bank does not have a branch in the host state. Federal Deposit Ins. Corp., Proposed Rules, Interstate Banking ; Federal Interest Rate Authority, 70 Fed. Reg. 60,019, 60,025 ( XXXX XXXX, XXXX ). Moreover, even as to national banks, state UDAP laws are not generally preempted. See Office of the Comptroller of the Currency, Exploring Special Purpose XXXX XXXX XXXX XXXX XXXX XXXX at XXXX ( XXXX XXXX ), XXXX XXXX XXXX the OCC has taken the position that state laws aimed at unfair or deceptive treatment of customers apply to national banks. ).

12 See CFPB Bulletin XXXX, Subject : Prohibition of Unfair, Deceptive, or Abusive Acts or Practices in the Collection of Consumer Debts ( XX/XX/XXXX ), XXXX : XXXX ; NCLC, Unfair and Deceptive Acts and Practices 6.10.

13 See NCLC, Fair Debt Collection 16.2.3.3.1 ( 10th ed. XXXX ), updated at XXXX

Company response to consumer: Closed with explanation