Bank gets NAL from CFPB utilizing template that is small-dollar

Bank gets NAL from CFPB utilizing template that is small-dollar


The Bureau issued a NAL to a national bank regarding certain small-dollar credit products offered by the bank on November 5, under the CFPB’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 bank’s application includes (i) each one of the “13 Guardrail Certifications” described into the template; (ii) a duplicate of this small-dollar credit product’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 teams’ template application. A duplicate associated with the bank’s application can be acquired right here.

Also, the Bureau circulated a Paperwork decrease Act (PRA) notice, addressing research efforts to “identify information that might be disclosed to customers through the cash advance process to greatly help them make better-informed choices.”

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