small dollar

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A group of 13 state attorneys general and the District of Columbia AG have sent a letter to the FDIC commenting on the agency’s request for information on small-dollar lending.  The RFI, published in November 2018, seeks input on “steps the FDIC could take to encourage FDIC-supervised institutions to offer responsible, prudently underwritten small-dollar credit products that are economically viable and address the credit needs of bank customers.”… Continue Reading

The FDIC has published a request for information (RFI) on small-dollar lending, including “steps the FDIC could take to encourage FDIC-supervised institutions to offer responsible, prudently underwritten small-dollar credit products that are economically viable and address the credit needs of bank customers.”  (The FDIC supervises state-chartered banks and savings institutions that are not Federal Reserve members.) … Continue Reading

With the August 19, 2019 compliance date for the CFPB’s small dollar lending rule drawing nearer, industry anxiety is growing as to the CFPB’s plans for delaying the compliance date and what changes will be proposed.  In this episode, we review what the rule’s ability to pay and repayment provisions would require and why those provisions are problematic. … Continue Reading

On July 26, 2018, the Federal Reserve Board (“FRB“) announced the launch of the “Consumer Compliance Supervision Bulletin” (the “Bulletin“) and simultaneously published its first issue.  Aimed at “senior executives in banking organizations,” the Bulletin is published by the FRB’s Division of Consumer and Community Affairs with the intent to provide high-level summaries of various consumer protection issues and to enhance the transparency of the Federal Reserve’s consumer compliance supervisory program. … Continue Reading

The bulletin issued yesterday by the OCC encouraging the banks it supervises “to offer responsible short-term, small-dollar installment loans” quickly met with mixed reviews from consumer advocates.

The Pew Charitable Trusts issued a press release in which it praised the OCC’s action for “remov[ing] much of the regulatory uncertainty that has prevented [banks] from entering the market [for small installment loans].” … Continue Reading

The OCC has issued a bulletin (2018-14) setting forth core lending principles and policies and practices for short-term, small-dollar installment lending by national banks, federal savings banks, and federal branches and agencies of foreign banks.

In issuing the bulletin, the OCC stated that it “encourages banks to offer responsible short-term, small-dollar installment loans, typically two to 12 months in duration with equal amortizing payments, to help meet the credit needs of consumers.” … Continue Reading

It will take a while to digest the CFPB’s nearly 1,700-page release on payday, title and high-rate installment lending but, naturally, I have a number of preliminary observations:

  1. It remains highly uncertain that the Rule will ever go into effect.  Once Director Cordray leaves office, his successor may have very different views on the costs and benefits of these products and may, at a minimum, want to assure himself or herself that there is a strong basis for the Rule. 
… Continue Reading

Earlier this week the CFPB released its Summer 2017 Supervisory Highlights, which covers supervisory activities generally completed between January through June of 2017. The report touts the $14 million total restitution payments consumers received due to nonpublic supervisory activities during this period-plus the approximately $1.15 million in consumer remediation and $1.75 million in civil monetary penalties resulting from public enforcement actions that grew out of or were bolstered by CFPB examinations.… Continue Reading

The Independent Community Bankers of America and the Credit Union National Association have sent a letter to Director Cordray “to express serious concerns” about the CFPB’s proposed rule covering single-payment payday and auto title loans, deposit advance products, and certain high-rate installment and open-end loans.

ICBA and CUNA state that the proposal “if finalized in its current form, would unquestionably disrupt lending by credit unions and community banks.” … Continue Reading

A group of Democratic Senators led by Oregon Senator Jeff Merkley is expected to introduce the “Stopping Abuse and Fraud in Electronic Lending Act of 2016” or “SAFE Lending Act of 2016.”

The bill represents the latest version of bills with similar titles introduced by Senator Merkley and other Democratic Senators in previous years.  … Continue Reading