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. As formerly included in InfoBytes, in might, the Bureau approved a template responding to a demand by a nonpartisan general public policy, research and advocacy team for banking institutions that will help depository organizations in providing a standardized, small-dollar credit item under $2,500 with a repayment term between 45 times plus one 12 months. The lender presented its application by using this template.
The NAL notes that the bankвЂ™s application includes (i) each of the вЂњ13 Guardrail CertificationsвЂќ described in the template; (ii) a copy of the small-dollar credit productвЂ™s terms and conditions the bank intends to provide to consumers; (iii) marketing useful source materials intended to be used to market the product; and (iv) substantially similar consumer benefits and consumer risks as described in the advocacy groupsвЂ™ template application among other things. (more…)