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Bank gets NAL from CFPB utilizing small-dollar template

Bank gets NAL from CFPB utilizing 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 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 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 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 groups’ template application among other things. (more…)