Agencies have offered realize that deposit advance products, often referred to as bank payday advances

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Agencies have offered realize that deposit advance products, often referred to as bank payday advances

Federal bank regulatory agencies have offered realize that deposit advance services and products, often referred to as bank “payday loans,” will be at the mercy of significant brand new limitations and heightened scrutiny that is supervisory. 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 in coordinated actions. [i] The Supervisory Guidance is available for remark for thirty days. [ii]

This informative article considers the proposed OCC/FDIC Supervisory Guidance in more detail, and additionally addresses the narrower a reaction to the CFPB research given by the Board of Governors for the Federal Reserve System (the “Board”) that relates to State chartered member banking institutions. [iii]

The OCC and FDIC are assertively making use of authority that is supervisory impose brand new limitations on deposit advance items.