Publications

Online Appendix: Bridging from emergency programs to longer term payment plans


Overview Paper

Report Summary


This study analyzes the potential benefits of combining temporary forbearance programs and longer term debt management plans (DMPs) during the COVID-19 pandemic. The research finds it may be helpful to evaluate whether particularly vulnerable and distressed borrowers need longer term repayment plans soon after they first enroll in natural disaster or other emergency relief programs with credit card lenders.

The study builds on a broader report (updated in August 2023) by FinRegLab and researchers at The Ohio State University and Charles River Associates that analyzes data organized by the National Foundation for Credit Counseling (NFCC) and credit records from Experian.

The working paper was released in August 2023 and updated in October 2023 to reflect the issuance of an online appendix with supplemental findings.

Acknowledgments


This empirical working paper is part of a broader research project organized by FinRegLab and the National Foundation for Credit Counseling to evaluate data, technology, and other innovations’ potential to help consumers recover more quickly from personal and economic crisis such as COVID-19. Support for this publication and other aspects of the project was provided by Bank of America, Capital One Financial Corporation, JPMorgan Chase, LendingClub, Synchrony, TD Bank, and the Wells Fargo Foundation. Detailed information about our funders can be found on the inside back cover.

The independent empirical research in this report has been conducted in collaboration with Dr. Stephanie Moulton and Rebecca Xie (John Glenn College of Public Policy at The Ohio State University).

Dr. Stephanie Moulton

John Glenn College of Public Policy at The Ohio State University

Rebecca Xie

John Glenn College of Public Policy at The Ohio State University

Coordination with the credit counseling agencies that contributed data for the analysis was facilitated by the National Foundation for Credit Counseling.

the National Foundation for Credit Counseling

Dedicated to educating Americans about how to reduce personal or household debt responsibly, the National Foundation for Credit Counseling is a trusted, nationwide resource for education and support in building financial management skills. Through its network of nonprofit agencies and certified counselors, the NFCC offers impactful approaches to debt reduction and improved credit standing, whether consumers are struggling with credit card debt, decisions about housing, or student loans. For more information about the NFCC or to be connected to a certified counselor, please call 800-388-2227 or visit www.nfcc.org.

We would like to thank Charles River Associates for their continuing involvement in our Distressed Borrowers project and David Silberman for his valuable feedback on this report.

David Silberman

Advisor

David Silberman has been involved in consumer finance issues from a wide range of perspectives for over three decades. As President and CEO of Union Privilege, an affiliate of the AFL-CIO, he led the development and oversaw the delivery of a range of consumer financial products and services to union members. After leaving Union Privilege, David served as General Counsel and Executive Vice President of the Kessler Financial Services, a privately-held company providing marketing and advisory services to financial institutions and their affinity-group partners. Following the passage of the Dodd-Frank Act, David joined the implementation team for the Consumer Financial Protection Bureau and was named the Associate Director for the Division of Research, Markets, and Regulations. In 2016-2017, David also served as the Acting Deputy Director for the CFPB. Mr. Silberman retired from the CFPB in 2020, and now serves as a Senior Advisor to the Center for Responsible Lending and the Financial Health Network’s Financial Solutions Lab. He also has been named an adjunct professor at Georgetown’s School of Public Policy and at Harvard Law School, from which he graduated. Mr. Silberman began his legal career as a law clerk to Chief Judge David Bazelon of the D.C. Circuit and Justice Thurgood Marshall.

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
FinRegLab

Colin Foos

FinRegLab

Gillous Harris

Research Analyst
FinRegLab

Zishun Zhao

Senior Data Scientist
FinRegLab

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

(www.capitalone.com) 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 www.jpmorganchase.com.

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 https://www.lendingclub.com.

Synchrony

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 www.td.com/us. Find TD Bank on Facebook at www.facebook.com/TDBank and on Twitter at www.twitter.com/TDBank_US and www.twitter.com/TDNews_US. 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 www.td.com/us.

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 www.wellsfargo.com | Twitter: @WellsFargo

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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 www.finreglab.org. Follow FinRegLab on LinkedIn and Twitter (X).

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