Bank gets NAL from CFPB utilizing small-dollar template

Bank gets NAL from CFPB utilizing small-dollar template

Bank gets NAL from CFPB utilizing small-dollar template

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On November 5, beneath the CFPB’s revised no-action page (NAL) policy, the Bureau issued a NAL to a nationwide bank regarding particular small-dollar credit first-rate web site to study services and products made available from the lender. 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 making use of this template.

The NAL notes that the bank’s application includes (i) each of the “13 Guardrail Certifications” described in the template; (ii) a copy of the small-dollar credit product’s terms and conditions the bank intends to provide to consumers; (iii) marketing materials intended to be used to market the product; and (iv) substantially similar consumer benefits and consumer risks as described in the advocacy groups’ template application among other things. A duplicate associated with bank’s application can be obtained right here.

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

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