Bank gets NAL from CFPB making use of small-dollar template
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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. As formerly included in InfoBytes, in might, the Bureau approved a template responding to a request by a nonpartisan general public policy, research and advocacy team for banking institutions that will help depository organizations in offering a standardized, small-dollar credit item under $2,500 with a repayment term between 45 times and something 12 months. The lender presented its application applying 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 payday loans in Louisiana application can be acquired right here.
Also, the Bureau circulated a Paperwork decrease Act (PRA) notice, addressing research efforts to “identify information that may be disclosed to customers through the cash advance procedure to assist them to make better-informed choices.”