Debt Resolution Options for Distressed Borrowers: Market & Policy Context

Overview Paper

Report Summary

As stakeholders ponder strategies to help consumers recover more quickly from personal and broader economic crises such as COVID-19, the Market & Policy Context report surveys the debt resolution options available to consumers who are struggling with credit cards and other general unsecured loans.

The report finds that current structures are often fragmented and prone to break when consumers experience a second financial hardship, and that the complex ecosystem can be overwhelming for consumers to navigate. It surveys available research, traces the historical evolution of related markets, and highlights issues and challenges with potential innovations going forward.

This report lays the foundation for FinRegLab’s empirical research with researchers from The Ohio State University and Charles River Associates using data from pilot programs organized by the National Foundation for Credit Counseling and other sources.


This report is part of a broader research project to evaluate data, technology, and other innovations’ potential to help consumers recover more quickly from personal and economic crises such as COVID-19. The independent empirical research described in the report is being conducted in collaboration with Professor Stephanie Moulton of The Ohio State University and Marsha Courchane and Adam Gailey of Charles River Associates, using data from member agencies of the National Foundation for Credit Counseling and other sources. This report lays a foundation for future subsequent empirical and policy analyses.

Dr. Stephanie Moulton

John Glenn College of Public Policy at The Ohio State University

Dr. Marsha Courchane

Vice President, Practice Leader of Financial Economics
Charles River Associates

Dr. Adam Gailey

Principal, Financial Economics Practice
Charles River Associates

Many of the insights in this report were derived from interviews with stakeholders in the financial services, technology, and civil society sectors. FinRegLab would like to thank stakeholders who participated in interviews and discussions, including members of our project Advisory Board. We would also like to thank individuals who provided valuable feedback on this report. They include:

Brad Blower

General Counsel
National Community Reinvestment Coalition (NCRC)

Mike Calhoun

Center for Responsible Lending

Kevin Moss

Kevin Moss Consulting LLC

David Silberman


Corey Stone

Senior Advisor
Oliver Wyman, Financial Health Network (FHN)

Chi Chi Wu

National Consumer Law Center

We would also like to acknowledge FinRegLab team members who worked on convenings, interviews, and reports related to this project. They include:

Kelly Thompson Cochran

Deputy Director and Chief Program Officer

Colin Foos


Gillous Harris

Research Analyst

With Support From

Bank of America

is one of the world’s leading financial institutions, serving individual consumers, small and middle-market businesses, and large corporations with a full range of banking, investing, asset management and other financial and risk management products and services. The company provides unmatched convenience in the United States, serving approximately 67 million consumer and small business clients with approximately 4,000 retail financial centers, approximately 16,000 ATMs and awardwinning digital banking with approximately 55 million verified digital users. Bank of America is a global leader in wealth management, corporate and investment banking and trading across a broad range of asset classes. Bank of America offers industry-leading support to approximately 3 million small business households through a suite of innovative, easy-to-use online products and services. The company serves clients through operations across the United States, its territories and approximately 35 countries. Bank of America Corporation stock (ATMs) is listed on the New York Stock Exchange.

Capital One Financial Corporation

( is a financial holding company which had $307.9 billion in deposits and $440.3 billion in total assets as of June 30, 2022. Headquartered in McLean, Virginia, Capital One offers a broad spectrum of financial products and services to consumers, small businesses, and commercial clients through a variety of channels. Capital One, N.A. has branches located primarily in New York, Louisiana, Texas, Maryland, Virginia, New Jersey and the District of Columbia. A Fortune 500 company, Capital One trades on the New York Stock Exchange under the symbol “COF” and is included in the S&P 100 index.

JPMorgan Chase & Co.

(NYSE: JPM) is a leading financial services firm based in the United States of America (“U.S.”), with operations worldwide. JPMorgan Chase had $3.9 trillion in assets and $313 billion in stockholders’ equity as of June 30, 2023. The Firm is a leader in investment banking, financial services for consumers and small businesses, commercial banking, financial transaction processing and asset management. Under the J.P. Morgan and Chase brands, the Firm serves millions of customers in the U.S., and many of the world’s most prominent corporate, institutional and government clients globally. Information about JPMorgan Chase & Co. is available at

LendingClub Corporation

(NYSE: LC) is the parent companyof LendingClub Bank, National Association, Member FDIC. LendingClub Bank is the leading digital marketplace bank in the U.S., where members can access a broad range of financial products and services designed to help them pay less when borrowing and earn more when saving. Based on more than 150 billion cells of data and over $75 billion in loans, our advanced credit decisioning and machine-learning models are used across the customer lifecycle to expand seamless access to credit for our members, while generating compelling risk-adjusted returns for our loan investors. Since 2007, more than 4 million members have joined the Club to help reach their financial goals. For more information about LendingClub, visit


is a premier consumer financial services company delivering one of the industry’s most complete digitally-enabled product suites. The company’s experience, expertise and scale encompass a broad spectrum of industries including digital, health and wellness, retail, telecommunications, home, auto, outdoor, pet and more. They have an established and diverse group of national and regional retailers, local merchants, manufacturers, buying groups, industry associations and healthcare service providers, which we refer to as our “partners.” They connect our partners and consumers through our dynamic financial ecosystem and provide them with a diverse set of financing solutions and innovative digital capabilities to address their specific needs and deliver seamless, omnichannel experiences. We offer the right financing products to the right customers in their channel of choice.

TD Bank

America’s Most Convenient Bank®, is one of the 10 largest banks in the U.S., providing over 9.8 million customers with a full range of retail, small business and commercial banking products and services at more than 1,100 convenient locations throughout the Northeast, Mid-Atlantic, Metro D.C., the Carolinas and Florida. In addition, TD Auto Finance, a division of TD Bank, N.A., offers vehicle financing and dealer commercial services. TD Bank and its subsidiaries also offer customized private banking and wealth management services through TD Wealth®. TD Bank is headquartered in Cherry Hill, N.J. To learn more, visit Find TD Bank on Facebook at and on Twitter at and TD Bank, America’s Most Convenient Bank, is a member of TD Bank Group and a subsidiary of The Toronto-Dominion Bank of Toronto, Canada, a top 10 financial services company in North America. The Toronto-Dominion Bank trades on the New York and Toronto stock exchanges under the ticker symbol “TD”. To learn more, visit

The Wells Fargo Foundation

The Wells Fargo Foundation is a private foundation that is funded by Wells Fargo & Company. In the communities we serve, we focus our social impact on building a sustainable, inclusive future for all by supporting housing affordability, small business growth, financial health, and a low carbon economy. News, insights, and perspectives from Wells Fargo are available at Wells Fargo Stories. Additional information may be found at | Twitter: @WellsFargo

Related Publications

  • Debt Management Insights for Distressed Borrowers

    FinRegLab is working with teams at The Ohio State University and Charles River Associates to evaluate new workout structures and data and technology applications for consumers who are struggling with unsecured credit. The project will use data from pilots organized by the National Foundation for Credit Counseling and other sources. Learn More

About FinregLab

FinRegLab is an independent, nonprofit organization that conducts research and experiments with new technologies and data to drive the financial sector toward a responsible and inclusive marketplace. The organization also facilitates discourse across the financial ecosystem to inform public policy and market practices. To receive periodic updates on the latest research, subscribe to FRL’s newsletter and visit Follow FinRegLab on LinkedIn and Twitter (X). | 1701 K Street Northwest, Suite 1150, Washington, DC 20006