New Restrictions On Bank “Payday Loans”

more+
less-

Federal bank regulatory agencies have served notice that deposit advance products, sometimes known as bank “payday loans,” will soon be subject to significant new restrictions and heightened supervisory scrutiny. In coordinated actions, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) announced proposed Supervisory Guidance that will mandate significant changes to the practices of State-chartered non-member banks and national banks offering such products. The Supervisory Guidance is open for comment for 30 days.

This Client Alert considers the proposed OCC/FDIC Supervisory Guidance in detail, and also addresses the narrower response to the CFPB study issued by the Board of Governors of the Federal Reserve System (the “Board”) that applies to State-chartered member banks.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Topics:  Compliance, Deposit Advances, ECOA, FDIC, Federal Reserve, FTC, OCC, Payday Loans

Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Dickinson Wright | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »