Usury Endorsed by the Government Is Repugnant
Usury is pernicious at best, but government-endorsed usury lite helping people in dire financial straits is flat out repugnant. There is just no justification for participation in this vile activity. Government-sanctioned usury lite is still hurtful to the downtrodden. There is never a valid reason to do the wrong thing. The NCUA through their proposed changes to the payday advance loan regulation is simply trying to justify doing the wrong thing by doing only a little less evil.
It is absolutely mind boggling that the regulator has the misguided need to raise a misguided usury ceiling during a historically low interest rate environment. During the Great Depression when the Federal Credit Union Act was signed, the ceiling was 12%. With cost of funds at truly all-time lows, it is questionable why a credit union would need a 35-point spread. If you are making loans for provident or productive purpose, it is difficult to imagine how extracting that interest rate out of an unfortunate member is on its face is not provident and questionable if it reaches productive standard.