The current hard economic times are felt by people globally. The situation is further confounded by consumers experiencing unexpected events that call for spending leading to a financial crisis.

Payday loans are usually attractive to relatively young people who may have responsibilities and need cash to foot bills that might have accumulated over time. Technology has revolutionized the way we do things and with the advent of online shopping that has become popular; consumers are able to purchase goods at the comfort of their living rooms.

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In November 2000, the OCC and OTS issued advisories to the CEOs of their regulated institutions “to highlight and discourage any abusive practices associated with payday lending.” These advisories promised “close review” of payday lending activities “through direct examination of the bank, examination of any third party participating in the trans- action under an arrangement described above, and, where applicable, review of any licensing proposals . . .”

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