I'm not sure how many people/how much money we're talking about but afaik fed data is missing fringe lending (payday loans, title loans, etc). If there's been a significant shift into those, we might be missing the picture.
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You bring up a good point and inline w/ my second point. Riskier side of the consumer loan market is usually utilized by under-served consumers; likely to be at the lower-end of income distribution. Debt service ratios are relative to discretionary income. Important issues melt into the mean.
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