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Predatory Lending

Conduct Screen Corporate Misconduct

Companies whose core business or significant revenue line involves extending credit on exploitative terms — payday lenders, title lenders, high-interest installment lenders, and financial institutions with documented patterns of predatory lending to vulnerable populations. The test is the lending terms and targeting, not simply being a lender. Distinct from financial_misconduct (which covers broader consumer financial harm).

12 companies currently excluded under this screen

Excluded Companies (12 total)

Showing 12 of 12 companies excluded under this screen.

Ticker Company Reason
SYF Synchrony Financial Synchrony Financial is a major issuer of private-label and co-branded retail credit cards, partnering with merchants to offer store-branded financing. A significant portion of its business involves extending credit to subprime borrowers through these retail channels, often at high interest rates. The company has faced repeated regulatory scrutiny and legal action over its lending practices. The Consumer Financial Protection Bureau (CFPB) has investigated Synchrony subsidiaries for deceptive marketing of medical credit cards and other promotional financing. Court documents from multiple settled class-action lawsuits reference Synchrony's use of mandatory arbitration provisions in customer agreements, a practice often criticized for shielding companies from accountability. Consumer complaints frequently allege predatory tactics, including intentionally delayed payment processing to trigger late fees and targeting vulnerable populations with high-cost credit products at the point of sale, such as in medical offices. While Synchrony operates in a regulated industry, its core business model relies on generating revenue from interest and fees on credit extended to consumers who may have limited alternatives, a characteristic of predatory lending. The pattern of regulatory investigations and consumer legal actions indicates systemic issues with the terms and marketing of its credit products.
JXN Jackson Financial Inc Jackson Financial Inc. (preferred series JXN-PA) is a major annuity provider whose subsidiary Jackson National Life Insurance Company has a documented pattern of predatory practices targeting elderly consumers. In a California class action, Jackson National agreed to pay up to $25 million to settle claims that it targeted customers aged 60 and older with fixed deferred annuities containing substantial undisclosed commissions, excessive surrender charges, and long surrender periods not properly disclosed under California law. The class covered over 44,000 consumers who purchased annuities between 2002 and 2012. In a separate settlement, Jackson National paid $8.75 million to resolve claims of incorrectly calculated withdrawal and recapture charges on Perspective Series, Elite Series, and Retirement Latitude variable annuities sold between 2009 and 2021. The core allegations — hidden fees, excessive surrender charges targeting seniors, and undisclosed commissions that adversely affect annuity values — are textbook predatory financial product design. Jackson reported $23.2 billion in total annuity sales for 2025.
NAVI NAVIENT CORP Navient, formerly the student loan servicing arm of Sallie Mae, systematically steered federal student loan borrowers into costly forbearance programs instead of more affordable income-driven repayment plans, causing balances to grow through capitalized interest. In January 2022, 39 state attorneys general reached a $1.85 billion settlement with Navient, canceling $1.7 billion in subprime private loan balances for over 65,000 borrowers and providing $95 million in restitution to 350,000 federal borrowers harmed by forbearance steering. The CFPB subsequently banned Navient from federal student loan servicing entirely in September 2024 and ordered $120 million in additional penalties, finding the company failed borrowers at every stage of repayment. The DOJ also resolved separate allegations of improper loan accounting and payment processing for $97 million in 2017.
PRAA PRA Group Inc Portfolio Recovery Associates (PRA Group), one of the largest debt collectors in the United States, is a repeat CFPB enforcement target. In 2015, the CFPB found PRA violated the Consumer Financial Protection Act and Fair Debt Collection Practices Act through deceptive collection practices. Despite the consent order, PRA continued the same violations. In March 2023, the CFPB filed a second action alleging PRA collected unsubstantiated debts, sued consumers on time-barred debts without required disclosures, failed to provide promised documentation, and furnished inaccurate information to credit bureaus in violation of the Fair Credit Reporting Act. The court ordered PRA to pay $12.18 million in consumer redress and a $12 million civil penalty, totaling $24.18 million. The CFPB characterized PRA as a repeat offender that ignored the terms of its prior consent order.
ECPG Encore Capital Group Inc Encore Capital Group, the largest debt buyer and collector in the United States, was sued by the CFPB in September 2020 for systematically violating a 2015 consent order. The CFPB found that Encore and its subsidiaries Midland Funding, Midland Credit Management, and Asset Acceptance Capital continued to sue consumers without possessing required account documentation, collected on time-barred debts without legally mandated disclosures, and failed to provide consumers with loan records they were entitled to receive. The violations affected hundreds of thousands of consumers. In October 2020, the court entered a stipulated final judgment requiring Encore to pay a $15 million civil penalty plus $79,309 in consumer redress and to comply with the original consent order for five additional years. The CFPB described Encore as a repeat offender.
UPBD Upbound Group Upbound Group, Inc. (formerly Rent-A-Center) operates a virtual lease-to-own business primarily through its Acima subsidiary, which the Consumer Financial Protection Bureau sued in July 2024. The CFPB complaint alleges Acima used “deceptive dark patterns” to obscure the true cost of agreements, hid key contract terms in fine print or behind pop-ups, and failed to provide required disclosures. The Bureau is seeking consumer redress and civil penalties. Upbound Group reported total revenue of $4.2 billion in 2022, with the virtual lease-to-own segment representing a significant and rapidly growing portion of its business following the Acima acquisition. The company’s own 2024 10-K filing acknowledges that being “perceived as engaging in abusive or predatory” practices by media or government agencies poses a material risk to its business.
SEZL SEZZLE INC Sezzle operates a buy-now-pay-later platform that extends credit to consumers who cannot access traditional credit cards or loans, charging late fees on missed installment payments. In January 2020, the California DFPI ordered Sezzle to cease making illegal unlicensed loans and refund fees collected from California residents. Hindenburg Research published a short report in December 2024 documenting that Sezzle borrows at 12.65% interest to lend to extremely high-risk consumers, that 41% of users reported late payments, and that active customers declined 20% and active merchants declined 51% since 2021 while credit loss provisions grew 130% year-over-year. The U.S. Senate Banking Committee opened an inquiry in November 2025 into consumer overextension and the company's fee practices. Insiders sold approximately $71 million in stock.
MTB M&T BANK CORP M&T Bank paid $64M (2016) to settle DOJ False Claims Act allegations for knowingly originating and underwriting FHA-insured mortgage loans that failed to meet HUD requirements (2006-2011). The bank identified "major error" loans internally but self-reported only seven to HUD, creating a quality control process that misrepresented defect rates. Whistleblower-initiated. Separately, a $3.3M class action settlement resolved allegations of illegal pay-to-pay fees charged to make mortgage payments online or by phone.
AXP AMERICAN EXPRESS CO CFPB ordered American Express subsidiaries (2012) to refund $85M to ~250,000 consumers and pay $27.5M in civil penalties for illegal credit card practices spanning the full customer lifecycle: deceptive marketing of enrollment bonuses, unlawful late fees, age-based discrimination in credit decisions, and failure to report consumer disputes to credit bureaus. Penalties split across CFPB ($14.1M), FDIC ($3.9M), Federal Reserve ($9M), and OCC ($0.5M).
MET METLIFE INC MetLife Bank paid $123.5M to DOJ under False Claims Act for knowingly originating ineligible FHA-insured mortgages (2008-2012). Elder fraud class actions (Cantor v. MetLife) document pattern of defrauding elderly investors with guaranteed high returns on diverted real estate securities.
ARES-PB ARES MANAGEMENT CORP Ares Management is a global alternative asset manager whose portfolio companies have been linked to predatory lending practices. The SEC fined Ares for compliance failures, and ViolationTracker documents a pattern of regulatory violations across its portfolio.
COF Capital One Financial CFPB suit (Jan 2025): cheated consumers out of $2B+ in interest by freezing 360 Savings rates while hiding higher-yield product. Dismissed by Vought admin — conduct documented. ACL ratio >4% confirms subprime structural model.

The Naughty List

A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.

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