Customer Finance Track

Customer Finance Track

CFPB, Federal Agencies, State Agencies, and Attorneys General

OCC lending that is small-dollar: one advance but one action right right right back?

The OCC has given a bulletin (2018-14) establishing lending that is forth core and policies and methods for short-term, small-dollar installment financing by national banking institutions, federal cost savings banking institutions, and federal branches and agencies of international banking institutions.

The OCC claimed it “encourages banking institutions to supply accountable short-term, small-dollar installment loans, typically two to one year in period with equal amortizing repayments, to assist meet with the credit requirements of customers. In issuing the bulletin” The bulletin is intended “to remind banks of this core financing axioms for prudently handling the potential risks related to providing short-term, small-dollar lending that is installment. ”

By means of back ground, the bulletin notes that in October 2017, the OCC rescinded its assistance with deposit advance services and products because continued conformity with such guidance “would have exposed banking institutions to possibly inconsistent regulatory way and undue burden because they willing to adhere to the CFPB’s final payday/auto title/high-rate installment loan guideline (Payday guideline). Continue reading