Woodstock Institute wrote two letters to federal regulators opposing Opportunity Financial’s (“OppFi”) application to acquire BNCCORP and BNC National Bank and be granted a bank charter, citing the Chicago-based lender’s extensive history of evading state rate cap laws to make loans in excess of 100% APR, including in Illinois. If granted a bank charter, the resulting new national bank will be able to offer high-cost lending products in states where it had previously been unable to do so legally.
The first letter zeroes in on OppFi’s evasion of Illinois’s 36% APR consumer loan rate cap law, the 2021 Predatory Loan Prevention Act. Five Illinois organizations joined Woodstock in opposing OppFi’s application: Capital Good Fund, Citizen Action/Illinois, Illinois People’s Action, Jewish Free Loan Chicago, and Legal Action Chicago.
The other letter, written in partnership with the National Community Reinvestment Coalition (NCRC) and Rise Economy, dives deeper into regulatory concerns surrounding this merger and OppFi’s history of harmful financial practices:
- OppFi agreed to pay a $2 million settlement to compensate consumers in Washington, D.C who were charged 160% APR and to stop making loans in D.C. over the local rate cap.
- The merged entity will have very limited Community Reinvestment Act (CRA) obligations despite its national footprint. OppFi intends to lend in all 50 states, but it is only proposing a single additional CRA assessment area while offering no guarantees regarding the future of its current North Dakota and Arizona assessment areas.
- OppFi’s double-digit charge-off rates for their consumer loans (55% in Q1 of 2026) are “virtually unheard of” in the banking world and raise serious questions about this acquisition’s potential impact on the financial stability of the US banking system.
- The Consumer Financial Protection Bureau’s complaint database has received over 1,600 complaints in the past 3 years related to OppFi’s “…high interest rates and lack of affordability…loan churning and cycle of debt concerns…”
