FDIC Guidance on Deposit Advance Products

Orrick - Finance 20/20
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On November 21, the FDIC issued final supervisory guidance to FDIC-supervised financial institutions with respect to the risks imposed by certain deposit advance products. The FDIC encourages banks to: (i) continue to offer these products, consistent with safety and soundness and other supervisory considerations and (ii) develop new or innovative programs to effectively meet the need for small-dollar credit. FDIC Release. Final Guidance.

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. Attorney Advertising.

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