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 submitted its application utilizing this template.
Among other items, the NAL records that the bankвЂ™s application includes (i) each one of the вЂњ13 Guardrail CertificationsвЂќ described when you look at the template; (ii) a duplicate of this small-dollar credit productвЂ™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 teamsвЂ™ template application. Continue reading “Bank gets NAL from CFPB making use of template that is small-dollar”