Integrity Advance Closed

What an Integrity Advance loan cost

Integrity Advance charged $30 per $100 borrowed per pay period — $24 for repeat customers. On its own that is standard payday pricing, and roughly comparable to a rate in the high hundreds annualised.

We do not publish a specific APR here because no court ever stated one, and the figures circulating online have no source we could verify.

The mechanism is what the CFPB documented. Loans automatically rolled over four times before any payment touched principal. Each rollover meant another full finance charge on the same untouched balance.

The Bureau’s worked example is stark: a $300 loan produced eleven payments totalling $1,065, of which $765 was finance charges. The borrower repaid more than three times what they received, on a loan they most likely expected to clear on their next payday.

The word "automatically" is doing the work. The borrower did not choose to roll the loan over four times; the product did it for them unless they intervened. That design is the entire difference between an expensive loan and a trap.

A six-year proceeding that changed nothing for borrowers

The CFPB filed its Notice of Charges on 18 November 2015 — three years after Integrity Advance had already stopped lending. An administrative law judge found liability in September 2016. The appeal was then held in abeyance pending PHH v. CFPB, and then Lucia v. SEC.

After Lucia suggested the ALJ had been improperly appointed, the whole thing was remanded for a new hearing. A second ALJ found for the Bureau in August 2020.

The Director issued a Final Order on 11 January 2021: $38,453,341.62 in restitution, joint and several, plus $7.5 million against the company and $5 million against CEO James Carnes personally.

The Tenth Circuit affirmed in full on 15 September 2022, rejecting every argument — constitutional structure, statute of limitations, and the appointment issue. The restitution and both penalties stood.

And then nothing happened. Integrity Advance does not appear on the CFPB’s published list of cases paying harmed consumers, under ongoing or closed cases. There is no claims website. Six years of litigation produced an unimpeachable judgment and, as far as any public record shows, no money for a single borrower.

The $12.3 million that went to his wife

Verified collection against the roughly $43.5 million owed amounts to $7 million — and that came from a second lawsuit, not the first.

In April 2023 the CFPB sued Carnes under the Federal Debt Collection Procedures Act, alleging he had fraudulently transferred $12.3 million from his revocable trust to his wife’s trust between 2013 and 2015 — that is, in the years after the lending stopped and before the charges landed. The timing is the allegation.

It resolved on 25 June 2024 with a stipulated judgment of $12,269,072.89, suspended on payment of $7 million within 210 days, credited against what he already owed. Suspension on that scale reflects a demonstrated inability to pay.

The lesson for anyone reading a settlement headline: a judgment is a number a court writes down. Whether it becomes money depends on whether the defendant still has any, and on whether anyone is left to chase it.