James Koster

@HumansNoContext Feels like the predatory MCA lenders and the regulators!

@aeroluft Miles didn't drive for the crowd. He drove because the car deserved to be driven correctly. That distinction — between performing for approval and pursuing truth because it matters — changed how I think about everything. I wrote about it.

Ken Miles — the man who drove for truth, not approval. A great piece from @Motor_Sport on the cars that defined him. His story changed how I think about excellence, purpose, and what it means to do something correctly simply because it deserves to be done correctly. The cars that made Ken Miles — Ford’s original enduro-mastermind motorsportmagazine.com/articles/sport…

Ken Miles didn't drive for the crowd. He drove because the car deserved to be driven correctly. That discussion - between performing for approval and pursuing truth because it matters - is what My Desert is about. jaykoster.substack.com/p/the-perfect-…

My Desert. The Introduction. The journey begins with naming. It ends with being named. jaykoster.substack.com/p/my-desert-in…

Predatory MCA Lending What if I told you there's an industry that charges small businesses interest rates up to 820% — and it's legal because they call their loans "receivables purchases"? @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending Every dollar of that fraud moved through the ACH network — the same system that processes your paycheck. Each transaction carried a bank's unconditional warranty that the amount was legitimately owed. It wasn't. @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending The Warranty What does "due and owing" mean? It means a fixed and settled obligation that is presently enforceable. The banks warranted that on every single debit. The formula that determines what's actually owed was never calculated. Not once. Across 87,180 agreements. @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending The Criminal Signal Three identical debits. Same amount. Same originator. Same merchant. Daily or weekly. Under an authorization that says payments should vary with actual revenue. That pattern is visible on any bank statement. It requires no investigation to identify. Just arithmetic. If a bank can deny a $3.50 coffee purchase in an unusual zip code in miliseconds, it can identify the MCA criminal signal. @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending The Law The Bank Secrecy Act requires banks to file Suspicious Activity Reports when they have "reason to suspect" criminal activity. Six enforcement actions across three agencies over three years have documented this exact pattern as criminal usury. After six — what's the reason NOT to suspect? @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

An excerpt from Chapter 1: The Bonds of Slavery, from my new book, My Desert Slavery doesn't always begin with chains. Sometimes, it begins with something that works. A plan. A system. A shelter from chaos. The kind of arrangement you would recommend to a friend if you cared about them: get yourself somewhere stable; get your feet under you; let the dust settle; don't make it harder than it already is. Refuge has a way of becoming residence. Residence has a way of becoming routine. And routine — when you're not paying attention — has a way of becoming your definition. That is why the Exodus story begins where it does: not with Pharaoh's whips, but with Egypt's competence. Before there is oppression, there is provision. Before there is cruelty, there is stability. Before there is bondage, there is a refuge that works — so well, in fact, that you almost miss the moment it starts to cost you. To see additional introductory material for My Desert, please visit ... jaykoster.substack.com/s/my-desert

Predatory MCA Lending The Count We analyzed one single ACH debit from a predatory MCA lender. One pull. One second. 17-21 potential federal and state criminal violations across five parties. Every party got paid. The only party that lost money is the small business owner. Full analysis: jaykoster.substack.com/p/anatomy-of-o… @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenatorTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending The Solution This isn't complicated. The rules exist. The laws exist. The pattern is arithmetic. No new legislation needed. No new agencies. No new technology. All the banks have to do is their jobs. All Nacha has to do is enforce its own rules. Why haven't they? @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems @SenatorTimScott @SenWarren @SenJoniErnst @SenMarkey Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Predatory MCA Lending The Close Yesterday we sent an open letter to @SenatorTimScott @SenWarren @SenJoniErnst @SenMarkey and both committees asking three simple questions. jaykoster.substack.com/p/open-letter-… Nacha won't answer them. The banks haven't been asked. The regulators haven't required it. Someone has to ask. The human cost is staggering. And it's still happening. @BankingGOP @SenateBanking @SenateSmallBiz @SmallBizCmteGOP @SmallBizDems Copied to @FinCENnews @FDICgov @FTC @NewYorkStateAG The human cost is staggering. And it's still happening.

Like telling your bank to return an unauthorized MCA payment!

I am the enforcer!

Is this the KYC banks are doing on predatory MCA lenders?