After rescinding its 2013 guidance sharply curtailing short-term, small-dollar loans often considered comparable to payday products, the Office of the Comptroller of the Currency has followed through with guidance actively encouraging national banks to make “responsible” short-term, small-dollar installment loans with terms between two and twelve months and equal amortizing payments. Although the FDIC has not withdrawn its companion restrictions on loans such as these and the FRB’s position remains unspoken, the path is now clear for national banks to offer loans that meet the needs of borrowers who rely on more costly products.
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