CFPB Problems No-Action Letter on Bank’s Small-Dollar Loan Program

CFPB Problems No-Action Letter on Bank’s Small-Dollar Loan Program

The CFPB issued a no-action letter to Bank of America saying that linked over here the agency will never just simply simply take enforcement action contrary to the bank associated with a small-dollar financing system. Particularly, the CFPB reported so it wouldn’t normally act under Sections 1031 („Prohibiting Unfair, Deceptive, or Abusive Acts or Practices“) and 1036 („Prohibited Acts“) of Dodd-Frank.

In line with the Bank of America no-action letter request, the financial institution’s small-dollar credit item („Balance Assist“) is organized being a fixed-term, amortizing small-dollar installment loan to be reimbursed over 3 months. The total amount Assist system would provide loans in increments of $100 as much as $500, having a $5 flat fee that is administrative regardless of quantity lent, along with hardly any other administrative costs charged. Bank of America specified that the total amount Assist item could be provided simply to customers with Bank of America accounts that are checking inflows surpassing a predetermined threshold. Further, the lender will execute a credit report about possible borrowers and that can reject individuals with a credit history that is poor.

The CFPB’s page provides that the no-action place can be acquired simply to Bank of America and never to virtually any other individuals. This is certainly in line with the scene expressed recently by Chair Heath P. Tarbert for the CFTC that a regulatory agency’s no-action position ought to be particular to a specific entity.

The insurance policy foundation because of this approach to no-action roles is maybe perhaps not apparent. As an over-all matter, what the law states ought to be the exact same for everybody. The following is an indicator: possibly someone else relying on the page should have to publicly reveal its identification, which may permit the regulator to advance evaluate the knowledge or success of this no-action page. In the event that function of the exclusivity is always to compensate the original receiver because of its work with acquiring the page, which can be reasonable, then that exclusivity period may be time-capped in light of this basic presumption that regulations should treat everyone else similarly. „CFPB Problems No-Action Letter on Bank’s Small-Dollar Loan Program“ weiterlesen

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