In the wake of last week's state Supreme Court victory for payday lenders, Ohio Sen. Sherrod Brown urged the Consumer Financial Protection Bureau to create rules that will reel in payday lenders not only in Ohio, but across the country.

In Monday's letter, Brown urged bureau director Richard Cordray to make sure its payday rules are expansive enough to address online payday loans; auto title loans, a similar product similar to payday that requires borrowers to pledge their cars as collateral; and installment loans, a product that payday lenders have retooled to carry triple-digit interest rates.

"Because most small-dollar, short-term loans possess three of the 'Four D's' that negatively affect consumers –deception, debt traps and dead ends –- the CFPB must address the full spectrum of products being offered," Brown wrote.

The Ohio Supreme Court sided with payday lenders last week in a unanimous ruling that the state's Short Term Lending Act did not bar payday lenders from using other lending licenses to issue payday loans.

Payday lenders had ignored the Short Term Lending Act, passed by both the legislature and voters in 2008. That, coincidentally, was the year Cordray was elected Ohio attorney general.

A number of states have had trouble driving out payday lenders and their triple-digit interest rates. After Texas passed a law restricting payday lenders, the companies declared themselves credit services organizations and continued high-cost lending, much as they have in Ohio. When Arizona let its payday law sunset in 2008, lenders began issuing car title loans instead.

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