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. The Bureau approved a template in response to a request by a nonpartisan public policy, research and advocacy group for banks that would assist depository institutions in offering a standardized, small-dollar credit product under $2,500 with a repayment term between 45 days and one year as previously covered by InfoBytes, in May. The bank 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 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. A copy associated with bankвЂ™s application is present right here.
Furthermore, the Bureau circulated a Paperwork decrease Act (PRA) notice, covering research efforts to вЂњidentify information that may be disclosed to customers throughout the pay day loan process to simply help them make better-informed decisions.вЂќ