Federal Banking agencies have differed ever since the OCC in 2013 imposed strict limits on the extent to which federally-chartered institutions could offer short-term, small-dollar loans and then again in 2018 when the OCC reversed itself to encourage more of the loans some castigate as predatory payday products that others believe are essential to lower-income households. Acknowledging in the early stages of the COVID crisis that job losses and other stresses have placed many families at unprecedented risk, the banking agencies initially issued a statement urging “responsible” lending in this sector.
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