White Paper No. 15
What a Manhattan Larceny Trial Reveals About the Boundary McCarran-Ferguson Never Drew
The Southwest Public Policy Institute (SPPI) is a 501(c)(3) nonprofit research institute and think tank dedicated to advancing better living through better policy.
Policy Brief
The FDIC’s State Bank Parity proposal would put state-chartered banks on national banks’ footing wherever they serve customers; by the agency’s figures, Illinois’s interchange law would cost those banks $308 million to move $2.28 million a year to merchants.
Policy Brief
Fifteen years into the debit card cap, Federal Reserve research finds that few merchants cut prices and that banks recovered much of the lost revenue from checking customers, a record that argues against extending the approach to credit cards.
In the News
AccountsRecovery.net reports on White Paper No. 13, in which Andrew Rodrigo Nigrinis examines the research the CFPB relied on for its medical-debt reporting rule.
Press Release
Former CFPB enforcement economist will expand the institute’s research on consumer finance, banking, and financial regulation.
White Paper No. 14
Why America’s Most Trusted Loan Is Its Most Expensive, and Who Decided Otherwise
White Paper No. 13
The CFPB’s Medical-Debt Reporting Rule
In the News
Six September pieces on what regulators may weigh, four coalition letters, and the late-July and August pieces our last roundups missed.
The Washington Times
Santa Fe New Mexican
The Washington Times
DC Journal
White Paper No. 14
Ranked by annual percentage rate, as American credit law ranks them, the 30-year mortgage is the second-cheapest of seven common credit products and the payday loan the fifth. Ranked by the finance charge as a share of what was borrowed, the payday loan is the cheapest of the seven and the mortgage the fifth.
The Moral Hierarchy of Debt
From Table 12. Parking, overdraft and payday rows use the disclosed or agency-reported fee. Credit card, auto and student rows are illustrative loans at indicative 2026 rates, amortized by the authors. The FHA row is the author’s Closing Disclosure; its finance charge includes mortgage insurance and prepaid finance charges.
| Product | APR (%) | Finance charge as share of principal (%) |
|---|---|---|
| Federal student loan | 6.39 | 36 |
| 30-year FHA mortgage | 6.548 | 121 |
| Auto loan | 7 | 19 |
| Credit card | 21.9 | 37 |
| Payday loan | 391 | 15 |
| Parking invoice | 14600 | 400 |
| Bank overdraft | 17000 | 142 |
84 op-eds and 3 letters in 27 outlets since 2022
Written by SPPI staff, by the year each one ran. The 3 op-eds from before SPPI’s founding in 2022 are in gray and not counted above.
The Wall Street Journal
Founded
Founded in Rio Rancho, New Mexico, and recognized by the IRS as a 501(c)(3) nonprofit in July 2022.
Released
SPPI’s first numbered white paper, on solar power’s actual share of the Southwest’s energy supply.
Joined
Approved as a partner of Atlas Network, a network of more than 500 free-market think tanks worldwide.
Released
SPPI’s first secret-shopper study: the three national banks Pew said offered small-dollar loans in New Mexico all turned down a well-qualified applicant.
Released
The test, extended to credit unions and a second state: 13 of 15 New Mexico credit unions denied the loan, offered no payday alternative loan or refused membership.
Resolved
The court rejected the Secretary of State’s motion to dismiss in April 2023. The office then settled, paying SPPI $22,000.
Launched
A campaign to collect accounts from consumers caught in the CFPB’s 2023 data breach, which exposed records on about 256,000 consumers. Fox Business covered the launch.
Awarded
Candid’s highest level of nonprofit transparency, awarded in 2024 and again in 2025 and 2026.
Testified
Testified against a rate cap on consumer loans, presenting the findings of No Loan for You! and No Loan for You, Too!
Testified
Testified against a 36% APR cap on consumer loans. SPPI’s written testimony is in the Senate Labor and Commerce Committee’s record.
Resolved
After a January 2025 trial, the court held SPPI entitled to its fees under the Inspection of Public Records Act. The department agreed to pay $30,796.93 in attorney’s fees, costs and tax.
Released
All seven credit-card applications made directly with lenders were rejected or left incomplete; through Credit Karma, the same applicant had a card within minutes. Fox Business reported the findings.
Filed
SPPI’s first federal amicus brief, with the James Madison Institute, supporting the Federal Reserve’s reading of the Durbin Amendment on debit-card fees.
Filed
An amicus brief with the Taxpayers Protection Alliance Foundation and the Pinpoint Policy Institute, supporting the Federal Reserve’s debit-card fee rule, Regulation II.
Released
A model act that would require the NAIC to report each year to a state’s insurance committees, as Michigan has required since 1998.
A monthly email with new research, testimony and op-eds.
SPPI is a 501(c)(3) nonprofit, and gifts are tax-deductible to the extent permitted by law.
