I am sure this post will get some people dancing in their
seats. But, as you celebrate the RAL problems, please remember that there are
good people, taxpayers and preparers, who are getting hurt.
I like domino displays. I admire the skill and patience of
the people who set them up only to have them knock themselves down in a few
seconds. All it takes is a little push on one to start it. Its fall causes the
second one’s fall and soon there is no stopping the cascade.
I don’t know what triggered the start of the RAL (Refund
Anticipation Loan) domino cascade. I don’t think much can be done to stop it
this year. I do know that the RAL industry is in crisis and good people are
going to get hurt.
RAL are short term loans based on the refund you expect to
receive. They are made after the return has been e-filed and usually approval
is within a day –two at the most.. They have been a target of community
organizations for years because of the high fees and they seem to target lower
income clients. They have also attracted people to the industry who are more
interested in the money to be made from fees than preparing a correct return.
Several years ago, the industry began to change. The
Department of Defense banned RALs for Military personnel and their spouses.
Pressure forced the banks which offered them to reduce the fees they charged.
This caused the banks to cut the incentives they paid to the software companies
and preparers. Then, just before Christmas, one of the banks (Santa Barbara
Bank and Trust – SBBT) which fund RALs, announced that regulators would not
approve their RAL program. Preparers scrambled to find a new bank to handle
their RALs but there were not a lot of options. SBBT was finally able to sell
their RAL division to the relief of their remaining preparer customers. But
this was short lived relief when business as usual actually became business
with no RALs. SBBT clients could only
offer the two week programs.
The shake up at SBBT affects everyone in the tax industry
who offers RALs. The other RAL banks increased their client base but does that
mean the same amount of loan money over more taxpayers and a higher decline
rate? How will the increased clients
affect customer service and processing times? What about the taxpayers who want
the RALs and change preparers? The original office will lose a client and the
new office many not have the resources to handle a large client increase.
Taxpayers many be waiting longer for appointments and receiving reduced
services or increased fees with the new preparer. And it’s not just the
independent offices which could be hurt. SBBT provided a major part of Jackson
Hewitt’s RAL funding. The last estimate was that 50% of their offices would not
be offering RALs.
Electronic filing opened last Friday, and over the weekend a
major part of the discussions on my tax forum was about the RALs; who had
approvals and how many were declined. Also, what reason is being given for the
declines? That was nothing new but this year there seemed to be more urgency
about the discussion. There is urgency on the part of the taxpayers too. News
reports have been showing up about riots at tax office. Riots caused because
taxpayers were not able to get their loan money when it was promised. This is
money the taxpayer were counting on receiving. Money, I am sure, many had
already spent. And just because there may not be a riot at the door does not
mean that there are not angry taxpayers at other offices. Taxpayers who are
waiting longer to learn they didn’t receive the loan or that the loan was for
less than they expected.
Something needs to be done about the RAL industry. I don’t
think much can be done this year. Also, I don’t think the banks involved can be
counted on to fix the problems. I expect the IRS or Congress will step in with
a patch. Maybe they’ll fix the problem but I doubt it. No matter what is done,
there will be small business owners who will be hurt. And there are taxpayers
who will get mad because they can’t get their refund when they want it. And
that is why this mess has happened. A need was created and fed. It grew without
supervision with everyone raking in the money. When supervision was proposed,
it was for the wrong reason and wasn’t enacted. Now the system is falling apart
one domino at a time.