Consumer complaint received 2026-05-27 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Payday loan
Issue: Charged fees or interest you didn't expect — 
Company: Minto Financial dba Minto Money
State: MD

Complaint narrative:
Formal Consumer Complaint to the Consumer Financial Protection Bureau ( CFPB ) Regarding : Predatory and Potentially Unlawful High-Cost Installment Lending Practices by XXXX XXXX XXXX Minto Money Loan # XXXX Complainant XXXX XXXX XXXX : XXXX XXXX XXXX XXXX XXXX, MD XXXX XXXX : XXXX XXXX ) XXXX Email : XXXX Loan Date : XX/XX/XXXX ( Agreement Date and Effective Date ) Date of Complaint : XX/XX/XXXX XXXX Summary I am submitting this formal complaint concerning a consumer installment loan I entered into with Minto Financial d/b/a Minto Money ( a claimed economic arm of the XXXX XXXX of Minto, a federally recognizeXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) XXXX The loan exemplifies predatory high-cost lending with an Annual Percentage Rate ( APR ) of 470.34 % an extraordinarily usurious rate that results in finance charges of {$3000.00} on a modest {$450.00} amount financed. The borrower is required to repay a XXXX of Payments of {$3400.00} ( nearly XXXX times the principal advanced ). This structure, combined with one-sided contract terms, a short cancellation window, aggressive default/acceleration provisions, and reliance on tribal sovereign immunity plus broad arbitration waivers ( including class-action and jury-trial waivers ), appears designed to evade applicable state consumer protection and usury laws while imposing unsustainable debt on consumers. These practices raise serious concerns under the Consumer Financial Protection Act ( CFPA ) regarding unfair, deceptive, or abusive acts or practices ( UDAAP ), Truth in Lending Act ( TILA ) compliance in substance ( beyond bare disclosures ), and potential coordination with or facilitation of schemes that circumvent federal and state lending regulations. I respectfully request that the CFPB investigate this lender, this specific transaction, and the broader business model for violations of federal consumer financial laws, coordinate with state attorneys general and other regulators, and take appropriate enforcement or protective action. Detailed Loan Terms ( from the XX/XX/XXXX Loan Agreement ) Key Disclosures ( Truth in Lending Disclosures section ) : Loan Type : Installment Loan Amount Financed : {$450.00} Finance Charge : {$3000.00} Total of Payments : {$3400.00} XXXX : 470.34 % Payment Schedule : XXXX payments, primarily {$210.00} each ( final payment {$200.00} ), due approximately monthly from XX/XX/XXXX, through XX/XX/XXXX. Fees and Default Provisions : XXXX XXXX : {$20.00} if payment is XXXX or more days late. The lender is authorized to debit the borrowers bank account for late charges. Refused Instrument Charge : {$30.00} for any dishonored payment ( ACH, check, etc. ). This can also trigger late fees and accelerate collection. Your Promise to Pay & Acceleration : Upon default ( missed payment, dishonored instrument, etc. ), the lender may declare the entire unpaid principal, all accrued finance charges, and other amounts immediately due and payable ( Accelerate Your Loan ). The lender may debit the borrowers bank account for the full accelerated amount. Prepayment : Allowed without penalty, but the borrower must contact customer service for an accurate payoff quote ; finance charges accrue until the actual prepayment date. XXXX XXXX : Extremely limited only until XXXX XXXX XXXX XXXXXXXX on the second business day after the Disbursement Date. After funds are deposited, cancellation requires returning the principal via debit authorization. This window is effectively illusory for most consumers once funds are received and spent. Governing Law, XXXX XXXX and Dispute Resolution : The Agreement is governed exclusively by the laws of the XXXX XXXX XXXX XXXX ( tribal law ), not the laws of Maryland or other states where the borrower resides or the loan is marketed/used. The lender asserts sovereign immunity as an instrumentality of the XXXX and states that nothing in the XXXX waives it except to the limited extent in the XXXX XXXX. Mandatory Arbitration Provision ( Consumer Arbitration Rules of the XXXX ) : Broadly defines disputes to include virtually all claims. It includes : Waiver of jury trial. Class-action / representative action waiver borrower can not participate in or bring class, private attorney general, or representative claims. XXXX in the XXXX XXXX of residence, but with significant limitations on procedure and remedies. The lender advances certain fees but the overall structure, paired with sovereign immunity, severely restricts meaningful consumer redress in court. Right to Opt Out of arbitration exists but is narrow ( written notice within 30 days, specific address/format ) and does not affect other terms. Other Key Consents : Broad consent to electronic communications, text messages, and telephone calls ( including potentially autodialed or prerecorded for marketing, collections, etc. ). Authorization for XXXX debits from the designated bank account ( XXXX Bank details provided in the agreement ) for disbursements, scheduled payments, late fees, refused items, and accelerated balances. The lender XXXX assign the Agreement without notice or consent. Disbursement & Funding : Loan proceeds were to be deposited via XXXX into the borrowers bank account. Delays can adjust the XXXX and Disbursement Date. Why This Loan Raises Serious Consumer Protection Concerns XXXX. Exorbitant, Unsustainable Cost of XXXX XXXX of 470.34 % on even a small installment loan produces finance charges more than XXXX times the principal. This far exceeds typical state usury caps ( often 1036 % for consumer or small loans ) and creates a high risk of debt spiral, especially for borrowers with limited income or on fixed assistance ( such as XXXX ). The long repayment schedule ( over 16 months ) turns what is marketed as short-term cash needs assistance into a prolonged, high-cost obligation. Special notices in the agreement itself acknowledge it is an expensive form of borrowing and not a solution for longer term financial problems, yet the economics make it precisely that for many consumers. XXXX. One-Sided Terms and XXXX XXXX XXXX combination of acceleration clauses, automatic account debiting authority, short cancellation window, and high fees for late or returned payments heavily favors the lender. Time is stated to be of the essence with no grace periods. These terms, when paired with the high principal-to-cost ratio, can trap consumers. XXXX. Apparent Attempt to Evade State and Federal Consumer ProtectionsBy structuring the loan under tribal law and asserting sovereign immunity, while marketing and disbursing to consumers in states like Maryland, the lender seeks to avoid state licensing, XXXX limits, small-loan regulations, and unfair/deceptive practices statutes that would otherwise apply. The broad arbitration clause with class/representative waivers further insulates the operation from collective or judicial scrutiny. Public records and litigation show this lender ( and similar tribal lending models ) has faced multiple class action lawsuits alleging rent-a-tribe schemes, usurious lending in violation of state laws ( e.g., Illinois Predatory XXXX Prevention Act and Interest Act ), consumer fraud, and XXXX claims. Rates in comparable loans have been reported in the 300700 % + APR range. Washington XXXX has issued consumer alerts regarding unlicensed activity by this entity or affiliates. These patterns support the need for federal scrutiny of whether the tribal affiliation is being used as a shield for practices that would otherwise be unlawful. XXXX. Potential UDAAP and TILA IssuesWhile TILA disclosures appear facially present, the substance of the product extremely high cost relative to benefit, aggressive collection authorizations, and barriers to redress XXXX constitute unfair or abusive acts or practices under the XXXX. The marketing of such products to consumers in financial distress, combined with the practical difficulty of early payoff or cancellation, warrants investigation. Requested Actions by the CFPB I respectfully request that the CFPB : Investigate XXXX XXXX XXXX XXXX Money, its XXXX XXXX ( including XXXX XXXX XXXX XXXX ), and XXXX XXXX XXXX or funders involved in originating, servicing, or collecting these loans. Determine whether this lending model and specific loan terms violate the Consumer Financial Protection Act ( UDAAP provisions ), Truth in Lending Act, or other federal consumer financial laws. Examine the use of tribal sovereignty claims and arbitration provisions as potential mechanisms to evade state consumer lending laws and licensing requirements applicable to loans made to residents of states such as Maryland. Coordinate with the Federal Trade Commission, state attorneys general, and banking regulators regarding rent-a-tribe or similar arrangements. Consider enforcement actions, restitution for affected borrowers, injunctive relief, civil penalties, and/or referrals for criminal investigation where evidence of fraud or unlawful debt collection exists. Provide public guidance or pursue rulemaking to address high-cost tribal lending practices that harm consumers. I am prepared to provide the complete XXXX XXXX XXXX and related authorizations ( including the full PDF with electronic signature records ), bank statements, payment history, and any other documentation requested. I can also be reached for an interview or to discuss the personal impact of this loan. This complaint is submitted in good faith based on the specific terms of the agreement I was provided and publicly available information about similar practices. I look forward to the CFPBs prompt attention to this matter and to protecting consumers from these types of high-cost, one-sided lending products. Sincerely, XXXX XXXX XXXX XXXX XXXX XXXX, MD XXXX ( XXXX ) XXXX XXXX Loan Reference : # XXXX ( XXXX XXXX XXXX XXXX Money )

Company response to consumer: Closed with explanation