The Bureau issued a NAL to a national bank regarding certain small-dollar credit products offered by the bank on November 5, under the CFPBвЂ™s revised no-action letter (NAL) policy. The Bureau approved a template in response to a request by a nonpartisan public policy, research and advocacy group for banks that would assist depository institutions in offering a standardized, small-dollar credit product under $2,500 with a repayment term between 45 days and one year as previously covered by InfoBytes, in May. The lender presented its application applying this template.
On top of other things, the NAL records that the bankвЂ™s application includes (i) each one of the вЂњ13 Guardrail CertificationsвЂќ described into the template; (ii) a duplicate of this small-dollar credit productвЂ™s terms and conditions the financial institution promises to offer to customers; (iii) advertising materials meant to be employed to promote the merchandise; and (iv) considerably comparable customer advantages and customer dangers as described within the advocacy teamsвЂ™ template application. A duplicate associated with the bankвЂ™s application can be acquired right here.
Also, the Bureau circulated a Paperwork decrease Act (PRA) notice, addressing research efforts to вЂњidentify information that might be disclosed to customers through the cash advance process to greatly help them make better-informed choices.вЂќ