# Guideline 3.2.2(ix) - Unacceptable Business Model: Predatory Loan Terms

**Guideline:** 3.2.2 · **Store:** Apple App Store · **Severity:** high · **Fix difficulty:** hard · **Typical turnaround:** 1-3 days

Canonical URL: https://appstorereject.com/rejections/apple/3/guideline-322ix-unacceptable-business-model-predatory-loan-terms

## Description

Apple is rejecting your lending or personal finance app because it offers loan products with predatory terms. Apple specifically prohibits apps that facilitate personal loans with APRs exceeding 36%, loans that require repayment in 60 days or fewer, and apps that access a user's Contacts to use as a collections or intimidation mechanism. This guideline was added in response to a surge of predatory lending apps, particularly targeting vulnerable populations. Apple now actively reviews lending apps for term compliance and has removed thousands of apps under this guideline. The 36% APR cap is a hard threshold -- there is no exception or appeal for higher rates. The 60-day minimum repayment period is equally firm. And accessing Contacts for any purpose related to loan collection or social pressure is an automatic rejection. Apple may also reject apps that access the user's photo library for intimidation purposes related to loan repayment.

## Common variations

- Loan APR exceeds 36% threshold
- Loan requires repayment in fewer than 60 days
- App accesses Contacts for loan collection purposes
- Loan terms not clearly displayed to borrower
- Predatory lending practices identified

## Example rejection email

```
Guideline 3.2.2(ix) - Business - Unacceptable

We found that your app facilitates personal loans with terms that do not meet App Store requirements. Specifically:

- The app offers loans with an annual percentage rate (APR) exceeding 36%.
- Some loan products require full repayment in less than 60 days.

Apps that facilitate personal loans must clearly display the annual percentage rate and the total loan cost. Loan APRs may not exceed 36%, and loan terms must be 60 days or longer.

Next Steps:
Please revise the app to ensure all loan products comply with the APR and term requirements, or remove non-compliant loan products.
```

## Resolution steps

## Quick Assessment
- **Risk level:** High (predatory lending apps risk permanent removal)
- **Resolution path:** Fix & Resubmit (restructure loan terms)
- **Typical turnaround:** 1-3 days

## The Fix

1. **Cap all APRs at 36%** -- Review every loan product offered through your app. No product may have an APR exceeding 36%. If your business model requires higher rates, you cannot distribute through the App Store.

2. **Set minimum 60-day repayment periods** -- All loan terms must be 60 days or longer. Remove any short-term loan products (payday loans, 7-day/14-day/30-day loans).

3. **Remove Contacts access** -- If your app requests access to the user's address book for any reason related to lending, collections, or social pressure, remove the Contacts permission entirely.

4. **Display APR and total cost prominently** -- Before a user commits to a loan, clearly show the APR, total interest, total loan cost, repayment schedule, and all fees.

5. **Ensure regulatory compliance** -- Beyond Apple's requirements, verify compliance with local lending regulations (TILA in the US, FCA in the UK, etc.).

6. **Remove intimidation features** -- If the app has any features that pressure borrowers (countdown timers, social sharing of debt, threats), remove them entirely.

## Prevention
- Design lending products with Apple's 36% APR cap and 60-day minimum in mind from the start
- Never request Contacts permission in a lending app
- Display all loan terms prominently and transparently
- Comply with all applicable lending regulations in addition to Apple's requirements

## Before / after examples

**Before:** App offers 14-day payday loans at 400% APR with access to user's Contacts for 'reference verification' that is actually used for collections pressure
**After:** App offers personal loans with a minimum 90-day term, maximum 35% APR, clear disclosure of all costs before commitment, and no Contacts permission
**Why it works:** Loan products must not exceed 36% APR, must have terms of 60+ days, and must not access Contacts for collections purposes.

## Common questions

**How long does this typically take to fix?**

Typical turnaround is 1-3 days (difficulty: hard). After resubmission, most re-reviews complete within 24-48 hours.

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*Machine-readable source: https://api.appstorereject.com/api/rejections/detail?slug=guideline-322ix-unacceptable-business-model-predatory-loan-terms*