When will Andrew Left of Citron Research get it? If he wants to criticize a company, then he should do so legitimately. His latest screed, packed with even more manure than his previous 3-part smear on World Acceptance Corp, has proven to this writer that he is deliberately spreading false information with intent to profit via shortselling.

Let’s get into his September 17th report and take it apart.

“World has built its entire business on loopholes… where its been able to curry the favor of state legislatures to open the loopholes in state usury laws so it can make sub-sub-sub-prime loans at super-high rates.”

False. State laws regarding consumer installment loans (CILs) do not contain loopholes. Each state in which World operates has carefully crafted, specific enabling legislation regarding CILs. World operates legally in every state, strictly according to these specific statutes.

Truth 1, Citron 0.

Left uses his usual inflammatory language to attack the quality of the loans and the rates charged. As anyone in the lending business knows, the rates that are charged are reflective of the risk assumed by the lender. World’s loans are extremely risky, since the borrower offers nothing tangible as collateral. Hence, the rates that reflect that risk and are specifically permitted under state law.

Truth 2, Citron 0.

“Any form of federal law, which has never existed, would supercede the many loopholes enabling WRLD to operate in their niche states… uniform Federal regulation by the CFPA would threaten World’s entire business model.”

False. Who says Federal law would threaten World’s business model? We haven’t seen any such regulatory language. Third, and most importantly, the proposal from the Obama Administration regarding the CFPA clearly states that it will not have any rate-setting authority!

And here’s the proof from the CFPA proposal, page 25, Section 1022:

(g) NO AUTHORITY TO IMPOSE USURY LIMIT.—Nothing in this title shall be construed as conferring authority on the Agency to establish a usury limit applicable to an extension of credit offered or made by a covered person to a consumer, unless explicitly authorized by law.

Truth 3, Citron 0.

Citron gets all hot and bothered over an op-ed by Elizabeth Warren, which I have previously torn to pieces. This quote, by the way, is from an op-ed. It is not a statement of policy. It is not a piece of legislation. It is not a piece of regulation. It is vapor because the CFPA does not exist, and because Elizabeth Warren has no credibility, just like Andrew Left.

Truth 4, Citron 0

Left reaches orgasmic ecstasy as his font become bigger and bolder, proclaiming that “the only remaining question is not whether World will come under uniform Federal regulation, but only the inevitable: how soon, and by whom?” He then quotes from a Washington Post article on the Fed’s extension of its regulatory umbrella to cover other non-bank financial products.

If you actually read the article and have been following the issue, what you discover is that the Fed is primarily concerned with bank subsidiaries operating in the sub-prime mortgage and home equity lending business — not CILs. And the last sentence makes it clear, “Lenders that are neither banks nor owned by holding companies remain beyond the reach of federal oversight.”

Truth 5, Citron 0

Left continues, “Everyone now realizes the need for uniform Federal regulation of consumer lending, and it has become inevitable.”

Everyone? Says who? Inevitable? Says who? I didn’t know Left had changed his name to Nostradamus. More unsubstantiated claptrap lacking supporting evidence of any kind.

Truth 6, Citron 0

“That step aligns all the parties — Congress, the Obama Administration and the Fed — in their intent: to protect the sub-prime consumer from predatory lending practices.”

Nope. Again, if you are at all familiar with the issue, CIL’s are not anywhere near a priority.

Truth 7, Citron 0

Left asserts, “And it won’t take a fixed interest rate cap to seriously impair World’s business. A more likely outcome is prohibition of the most abusive practices of “flipping” and “packing” — which is more than enough to devastate World’s cash flow and viability.”

What Left fails to mention is that I, as well as the company in its conference calls, have repeatedly debunked the notion of “flipping”. You can read about it here.

As for “packing”, credit insurance is voluntary and is expressly authorized by the customer in World’s truth and lending disclosures, and insurance authorization forms. It is illegal to package insurance products for sale, or make them in any way a condition for loan approval. This is enforced by the Federal Trade Commission. World does not engage in packing.

Furthermore, unearned portions of credit insurance charges are rebated to the customer upon prepayment in full of their loan obligations.

Since there is no flipping or packing, there is no threat from regulation.

Truth 8, Citron 0

Left concludes this portion of his masturbatory rant by insisting that all of his assertions will kill World. Of course, since his assertions consist of eight lies and no truth, we dismiss this conclusion as faulty at best, and of dubious motive at worst (more on that shortly).

Truth 9, Citron 0

We’ll pass over the first paragraph of his next section about something smelling funky (and it isn’t World’s books, by the way) as it’s a rehash of what I’ve already tackled.

Left then diddles with a few paragraphs over how credit quality is deteriorating, and raises skepticism about World’s loan loss reserves. His thesis appears to be that World’s business model can’t possibly survive given the unemployment situation, and accuses World of cooking the books to show lower loan losses than reality.

Except Left is lying, again. Even worse, he’s accusing the company of malfeasance. It’s amazing what guys like Left can get away with, and I’m surprised that World doesn’t sue for libel — because discovery would likely show that Left is short the stock and has intent to defame World so that he may profit.

Here are the facts. Actual loan losses cannot be controlled by the company. But the P&L clearly indicates that actual loan losses have remained relatively consistent. Loan loss is different from loan loss reserves — the amount the company sets aside against income. The company has stated on numerous occasions that the loan loss reserve is their most important estimate and that they, and their external auditors, analyze it on an ongoing basis using several models to determine the adequacy of the estimate. Historically, as long as charge-off ratios remain within a certain band, the company has stated that they believe this current approach is reasonable.

Left’s allegation that World has been lowering reserves as a percent of net loans in a material way is an outright lie. Yes, there will be fluctuations on a quarterly basis, but World’s methodology has been consistent for a long time.

Left then has the audacity to proclaim that World’s methods are creative and ridiculous.

Pot, meet kettle.

Truth 10, Citron 0

Left tries to draw parallels between HFC and World, but there is no comparison between the two entities. HFC opened in the 1970’s, primarily offering secured consumer loans of $500 – $5000. Over time their model changed, where small loans became feeders for their mortgage operations. After being acquired by HSB, the real estate market went bad, and their adjustable mortgages defaulted. HFC was out of business — not because of CIL’s, but because they had become a mortgage lender.

World is not in the mortgage business at all.

Citi Finance, also known as CIT, is primarily a lender to small businesses.

World is not in the small business loan arena at all.

Truth 11, Citron 0

At this point, Left has thrown out any pretense. He’s moved from active liar to pathological liar.

“It is the opinion of Citron Research that by serially flipping and re-writing loans 45 days delinquent, (a “service” which World discloses it “actively markets to its customers”) the company masks the true low quality of its receivables. Further, by its own admission, it also rewrote over $40 million in loans from its own “delinquent” status (beyond 45 days overdue).”

Absolute fantasy. As stated in SEC Filings, these loans totaled less than 2% of all origination volume last year. This number has remained consistent for years. Loans that are renewed more than 45 days contractually delinquent are never increased to any larger size.

In addition, most of that tiny 2% are for customers who have paid monthly payments recently, but are contractually past due from prior missed payments resulting from job loss or unexpected expenses. They can make the monthly payments, they just can’t catch up contractually. World will renew those loans, but do so using a new application, credit bureau report and evaluation of the customer’s ability to pay.

How responsible is this? Very. And it’s the same tactic the Obama Administration asked mortgage lenders to do for their delinquent loans.

Truth 12, Citron 0

Left continues, “Even states that aren’t actively rewriting laws to curb the abusive practices of WRLD and other installment lenders are actively establishing alternatives to extend credit to WRLD’s type of customer.” He cites an article describing a plan in Dallas.

Except this plan 1) is intended for payday lending and check-cashing customers, neither of which are World’s clientele, and 2) even if they were, these types of plans are simply being tested, and so far have been utilized infrequently. Neither the payday loan or check cashing industry has been affected by any of these small alternative programs because they are too tiny to make any impact.

Truth 13, Citron 0

Had enough? We aren’t done. Left puts on the clown makeup and red nose and starts honking about how World is lending to the military at rates exceeding the 36% APR rate cap. Honk! Honk!

Except CIL’s are not subject to this rate cap. Only payday loans, tax refund anticipation loans, and auto title loans are subject to the cap. In fact, the department of defense, when setting the cap rules, made specific reference for the need of “legitimate, safe, regulated small loan consumer credit” when they prohibited the other practices, which were defined specifically by the DoD as being non-beneficial forms of credit.

A simple glance at Page 50585 of The August 31, 2007 Federal Register, “Limitations on Terms of Consumer Credit Extended to Service Members and Dependents: Final Rule” clearly states:

“…the final rule focuses on three problematic credit products that the Department identified in its August 2006 Report to Congress on the Impact of Predatory Lending Practices on Members of the Armed Forces and Their Dependents: payday loans, vehicle title loans, and refund anticipation loans. The Department’s definition of the term ‘‘consumer credit” in the proposed rule was intended to narrow the regulation’s impact to consumer credit products and services that are potentially detrimental and for which there are DoD-recommended, alternative products or services available to Service members and their dependents. DoD believes that a narrow definition will prevent unintended
consequences while affording the protections granted by the statute.”

World is operating within the law.

Truth 14, Citron 0

“It is Citron’s opinion that WRLD has intentionally grown its business of usury-rate lending to members of the US military. As soon as this loophole is closed, so go those “best offices”.

There is no loophole since World is operating legally.
Approximately 1.5% of World’s loans are made to military personnel.
Nowhere does World claim these are their best offices.

That’s a 3-for-1 lie.

Truth 17, CItron 0

And to wrap things up, ” World’s business window is narrowing in both time and geography. While it waits for Federal regulation, it can’t meaningfully expand its eleven-state operations to any new states if it loses one or two. ”

World doesn’t seem concerned. It is expanding domestic operations.

Truth 18, Citron 0

“As a source of growth, its Mexico initiative is obviously failing to generate profits or growth. ”

World’s most recent quarterly reports that they had a total of 63 offices in Mexico with the stated goal of adding 15+ the remainder of the year. They service over 70,000 customers and have $366 million pesos in loan balances outstanding. That would be growth that began from zero stores and zero loan balance. Looks pretty good to me.

Truth 19, Citron 0

The only question that remains — and frankly, I don’t think it’s even a question anymore — is whether Left is just plain stupid and lazy to miss all the facts I have been so easily able to root out, or if he is deliberately lying.

My three previous articles completely exposed Left’s attacks on World as being filled with misstatements of fact, insidious innuendo, and outright lies. Rather than rebut those articles directly and defend his position, Left continues to press a case built on a house of cards. He is obviously not interested in the truth. In his case, we also have his personal legal record to consider.

Back in 2000, the National Futures Association (a regulatory agency watching over the commodities and derivatives markets) found that Left had made “false and misleading statements to cheat, defraud, or deceive a customer”. He was barred from “association with and from acting as a principal of any NFA member for three yeras, ordered him to take an ethics training course, and placed restrictions on his activities…” (Source: NFA Case ID# 0253075)
Then there was the little matter of Left being sued for Fraud and Deceit, Negligent Misrepresentation, and Breach of Fiduciary Duty — a case which he lost and was ordered to pay restitution for.
Double oops.
So, we have a known short-seller with a previous history of ethics violations and check fraud, who has written three articles loaded with false statements that have been completely discredited.

As my old math teacher once said, “Take a moment to think before following the White Rabbit down that hole”.
So just as Left claims to put out his information and let the reader decide, I’ll do the same.

How is this actionable?

Last time, Left’s articles were arguably a reason why the stock sold off from $28 down to $17. After I published my rebuttals, the stock recovered, eventually returning to $28. Since his latest missive was released on Sept. 17, the stock is off 10%.

Right now, you have WRLD trading at about 7 times current earnings and less than 6 times earnings on forward earnings of $4.24 for its year ending March, 2011. At 11% projected growth for next year, I see a stock trading at a 40% discount to intrinsic value.

The company has strong cash flow, and more importantly, if the company had to liquidate its portfolio at the current loan loss rate of 16%, the company would still have $13.50 in net cash on its books. Not only is such an event ridiculous unlikely, it won’t result in the claim that the stock would “go to zero”.

In addition, October 25 calls are going for a nice 6% premium. That’s a nice return to buy the underlying and sell the calls.

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