Goal: Smarter growth.
Which states where storefronts and online lenders actually operate and why.
You will see APR ceilings, CAB options, and enforcement heat.
Use it to stop wasting time on bad markets and focus on states that welcome your model.
Where to Expand Next: APR Realities by State (as of 2025)
I created a field ops plan: map the actual APR ceilings, CAB options, and enforcement heat, then ranked states so you stop chasing dead markets.
Below is a tight, evidence‑based playbook you can act on now.
NOTE: This APR list by state became obsolete the moment I created it. State regs change...
Prefer to read online Blog Post
1) Key Challenges (with data)
Regulatory volatility & patchwork caps
Recent waves of 36% APR caps fundamentally reshaped markets (e.g., New Mexico to 36% effective Jan. 1,
2023; Illinois 36% since 2021; Virginia 36% since 2021), forcing model shifts or exits. (1)(2)(3)
Local overlays that change unit economics
In Texas, statewide CAB remains viable, but 49 cities adopted “unified” ordinances limiting loan size/rollovers—turning some metros from A+ to B/C even with no state cap. (4)
Databases & supervision raise compliance costs
Nevada turned on a statewide database for deferred deposit, title, and high‑interest loans in Feb. 2022 (SB201), adding front‑end eligibility checks and audit trails. (5)(6)
Florida requires a real‑time database and caps fees at 10% + $5 verification for $50–$500 DPP loans. (7)(8)
Online vs. storefront: same license, different scrutiny
Utah has no usury ceiling (unconscionability standard), enabling very high APRs; most activity is online or hybrid, but litigation and media scrutiny can spike perceived risk. (9)(10)
Wisconsin licenses consumer “loan companies” to exceed 18% APR and
runs a payday database—permissive but supervised. (11)(12)
Title loan divergence (pawn vs. credit)
Georgia treats auto‑title lending as pawn with caps of
25%/month for the first 90 days and 12.5%/month thereafter (effective max ~187.5% APR), and the state banking agency does not license title pawns; enforcement is mostly local. (13)(14)
Idaho allows title loans (statute sets renewals and 10% principal reduction
after the 3rd renewal; no explicit APR ceiling specified in the Title Loan Act). (15)(16)
2) Analysis of Challenges (root causes, who’s affected, current responses)
Volatility/caps stem from multi‑year advocacy and bipartisan pushes for <36% APR “all‑in” thresholds; borrowers in cap states often shift to longer‑term installment, credit‑builder, BNPL, or informal credit.
Operators either re‑paper under consumer‑finance licenses at ≤36% or exit (e.g., IL PLPA drove exits of high‑cost storefronts; VA Fairness in Lending Act eliminated classic title loans). (2)(3)
Local overlays (TX) arose because the Legislature didn’t impose statewide rate caps; cities responded with unified ordinances (loan size ≤ 20% of monthly income, limits on renewals/refinance, etc.). CAB is still workable but unit economics vary by ZIP code. (4)(17)
Databases (NV, FL, WA, etc.) curb concurrent loans and enforce cooling‑offs; they don’t ban products but reduce churn revenue and increase K‑compliance costs and charge‑off exposure visibility. (5)(6)(7)(8)
Online vs. storefront: regulators increasingly treat them the same (licensing, disclosures, EPPs),
but reputational risk rises online. Utah/Idaho/Wisconsin remain permissive but active—complaints and press can trigger statutory tweaks. (9)(10)(11)(12)
Title lending splits: pawn‑law states (GA) remain attractive for APR flexibility and renewals; “credit‑code” states (ID, MO, NH) provide pathways with disclosures, renewals, and
specific fee rules; prohibition/cap states (VA, CO, NM, IL) are effectively off‑limits for legacy high‑APR title models. (13)(15)(18)(3)(1)(2)
3) Where to Expand Next (shortlist with why)
Tier 1 — Most welcoming today (storefront + online)
Good APR flexibility, workable oversight, proven operator presence.
Texas (CAB model) — No statewide cap on total charges under CAB (fees + third‑party loan), very large market; manage 49‑city ordinances and keep a clean compliance program. (16)(4)
Utah — No
interest‑rate ceiling (unconscionability standard). Clear deferred‑deposit registration and consumer guidance; strong online acceptance. (9)(10)(19)
Nevada — High‑interest loans legal; statewide database live since Feb. 2022; both payday and title lending operate at scale. (5)(6)
Wisconsin — Licensed “loan companies” can exceed 18% APR; payday tracked via state database; permissive but supervised environment. (11)(12)
Tier 2 —
Attractive with defined guardrails
Georgia (Title Pawn) — APR effectively up to ~187.5% on renewals; state DBF does not license pawnbrokers (local licensing); strong title pawn tradition. (13)(14)
Missouri — Payday: fees/interest capped at 75% of principal on initial + renewals; 14–31 day terms; title lending authorized under Ch. 367. (20)(21)(22)
Florida — Predictable: 10% fee + $5 verification;
database; 7–31 day term. Lower yield than TX/UT but very stable, very large. (7)(8)
Tier 3 — Niche/Title‑forward or selective
Idaho (Title Loan
Act) — Renewals allowed; 10% principal reduction after 3rd renewal; statute doesn’t set a numeric APR ceiling; licensing via Dept. of Finance. (15)(16)
New Hampshire (Title) — Explicit cap of 25% per month (300% APR) for title loans; in‑state office required. (23)
No‑Go / Re‑paper only at ≤36% APR
Illinois (PLPA 2021, 36% APR cap) (2)
Virginia (36% APR cap; title loans ended under VFIA) (3)
New Mexico (36% APR cap effective 2023) (1)
Colorado (longstanding 36% framework for small‑dollar loans) (24)
4) State Snapshots: APR ceilings, CAB options, enforcement heat
Texas — Model: Credit Access Business (CAB) brokering third‑party payday/title loans; no statewide cap on total charges; 49 cities with unified ordinances (loan size & refinances); OCCC licenses CABs
and publishes guidance. Enforcement heat: city‑level + OCCC exams; high advocacy attention. (16)(4)(25)
Utah — Model: Deferred deposit & title lending permitted; no usury ceiling (unconscionability std., Utah Code 70C‑7‑106); DFI guides/monitors; EWA also now regulated (2025).
Enforcement heat: moderate; reputational scrutiny. (9)(10)(26)
Nevada — Model: Payday, title, and “high‑interest” loans regulated; database required (SB201) for eligibility/front‑end enforcement. Enforcement heat: moderate—FID database compliance. (5)(6)
Wisconsin — Model: Loan companies >18% APR (s. 138.09); payday database; eligibility checks mandated. Enforcement heat: moderate database compliance; otherwise permissive. (11)(12)
Georgia (Title Pawn) — Model: Pawn statute; 25%/mo first 90 days; 12.5%/mo thereafter; GDBF doesn’t license pawnbrokers (local ordinances apply). Enforcement heat: local. (13)(14)
Missouri — Model: Payday ≤$500, 14–31 days, 75% of
principal cap on interest/fees; renewals ≤6; Title loans authorized/regulated (Ch. 367). Enforcement heat: Division of Finance licensing/exams. (20)(22)(21)
Florida — Model: Deferred Presentment Program: 10% fee + $5 verification, $50–$500 loans,
7–31 days, statewide database. Enforcement heat: steady and predictable. (7)(8)
Idaho (Title) — Model: Title Loan Act sets 30‑day loans with automatic renewals; 10% principal reduction starting at 3rd renewal;
disclosures; default & prohibited actions detailed; no numeric APR listed in statute. Enforcement heat: licensing & exams. (15)(16)
New Hampshire (Title) — Model: Title loans capped at ≤25% per month; physical office in‑state. Enforcement heat:
Banking Dept. exams. (23)
5) Innovative Solutions (to operationalize “smart growth”)
A) State Market Attractiveness Scorecard (SMAS)
Core purpose: Rank states quarterly on yield vs. survivability.
Key
components:
Statutory yield: APR/fee ceilings and product restrictions. (7)(8)(13)(20)(23)
Operational friction: presence of databases (NV, FL), city ordinances (TX). (5)(6)(4)
Licensing path: CAB (TX), pawn (GA), consumer‑finance license (others). (16)(14)(11)
Heat index: recent AG/CFPB actions, media, legislative momentum (NCSL trackers). (27)
Value proposition: Prevents sunk cost in newly capped/prohibited states; shifts capital to Tier 1/Tier 2.
Implementation: Small data warehouse (statutes + regulator PDFs); scraper/alerts for NCSL and state registers; monthly counsel review.
B) Regulatory Early‑Warning System
Core purpose: Detect bills that would cut APRs or add databases 1–2 sessions ahead.
Features: NCSL bill feeds; keyword monitor (“deferred deposit,” “title loans,” “36% APR,” “database”); counsel triage. (27)
Value: Moves you out (or re‑papers to ≤36%) before the cliff.
C) Dual‑Track Product Architecture
Core purpose: Flip between high‑yield and ≤36% installment in hours, not months.
Features:
Pre‑approved ≤36% templates for IL/VA/NM/CO (with allowable origination fees per statute where applicable). (2)(3)(1)(24)
For TX, maintain CAB
documents + city‑compliant loan sizing. (16)(4)
For NV/FL, database adapters in your LMS. (5)(7)
Evidence: Operators that re‑papered to ≤36% stayed live in VA/IL post‑reforms; state reports show continued lending under new frameworks. (3)(2)
D)
Geo‑Targeted Texas Strategy (CAB)
Core purpose: Maximize TX’s unmatched demand while avoiding ordinance traps.
Features: City‑by‑city playbooks; auto‑calculated loan size caps vs. income; refinance counters; audit‑ready
disclosures. (4)(16)
Value: Keeps TX Tier 1 across metros without enforcement headaches.
E) Title‑Forward Micro‑Footprint
Core purpose: Use title pawn/loan in GA, ID, NH to seed new markets with smaller capex.
Features: Mobile underwriting + e‑perfected liens where allowed; renewal logic per law (ID 10% principal reduction; GA renewal cycles). (15)(13)
Value: Faster to
first‑dollar with high ticket/strong collateral.
6) Solution Framework (what to build)
For each initiative above, I’d implement:
Core functionality: Centralized rules engine that determines allowed APR/fees, term, rollovers, EPPs, database hits,
and city caps per borrower ZIP and product.
Key components:
Statute/config service (per state + city);
LMS integrations (NVLDS, FL OFR, TX CAB fields);
Doc‑gen with state‑specific disclosures (e.g., ID renewal notices; GA pawn ticket). (5)(7)(15)(13)
Value evidence: State agency reports show databases reduce prohibited concurrent loans; compliant models persist (FL, NV). (7)(6)
Requirements: Counsel review per state; NMLS licensing where required; periodic audits tied to regulator calendars. (11)(12)(19)
7) Quick Reference — Selected APR/term rules you’ll actually use
TX (CAB): No statewide cap on total charges under CAB (fees aren’t “interest” for
usury); city ordinances apply. (16)(14)(4)
UT: No usury limit; unconscionability standard under 70C‑7‑106; DFI consumer guide confirms no ceiling. (9)(10)
NV:
Database required (SB201) for payday/title/high‑interest loans; eligibility verification mandatory. (5)(6)
WI: Loan companies may exceed 18% APR (s. 138.09); payday lenders must use DFI database. (11)(12)
GA (Title Pawn): ≤25%/mo first 90 days; ≤12.5%/mo thereafter; state DBF does not license pawnbrokers. (13)(14)
MO (Payday): Loan ≤$500, 14–31 days, ≤75% of principal total interest/fees; renewals ≤6. (20)
FL (DPP): Fee 10% + $5 verification; $50–$500; 7–31 days; mandatory database. (7)(8)
ID (Title): 30‑day loans; automatic renewals allowed;
10% principal reduction at 3rd renewal+; no numeric APR cap in Title Loan Act. (15)(16)
NH (Title): ≤25%/month cap; in‑state office. (23)
No‑go high‑cost: IL (36%), VA (36% + title ban), NM (36%), CO (36%). (2)(3)(1)(24)
8) Conclusion & Next Steps
Bottom line:
For high‑yield scale today, I would prioritize TX (CAB), UT, NV, WI, then
GA title, MO, FL, with ID/NH as title‑forward satellites.
Avoid launching legacy high‑APR products in reform states (IL/VA/NM/CO). (1)(2)(3)(5)(7)(8)(9)(13)(20)(24)
Action plan (next 30–60 days):
Stand up the State Market Attractiveness Scorecard and wire bill‑tracking alerts (NCSL). (27)
Build city‑compliant TX loan sizing + refinance logic; pre‑clear your top five TX metros (expect ordinance variance). (4)(16)
Plug NVLDS and FL database adapters into your LMS; run UAT with real scenarios. (5)(7)
Ship dual‑track docs so you can issue ≤36% installment in cap states on demand. (2)(3)(1)(24)
Pilot GA title pawn (one metro), UT online, WI storefront—compare
CAC, loss curves, and compliance ops load.
