Bank gets NAL from CFPB making use of template that is small-dollar

Bank gets NAL from CFPB making use of template that is small-dollar

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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 submitted its application utilizing this template.

Among other items, the NAL records that the bank’s application includes (i) each one of the “13 Guardrail Certifications” described when you look at the template; (ii) a duplicate of this small-dollar credit product’s terms and conditions the lender promises to offer to customers; (iii) advertising materials meant to be employed to promote the item; and (iv) considerably comparable customer advantages and customer https://paydayloansnc.org/ dangers as described into the advocacy teams’ template application. Continue reading “Bank gets NAL from CFPB making use of template that is small-dollar”