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Proposed Guidance on Deposit Advance Products – IBA Compliance Connection

Proposed Guidance on Deposit Advance Products

Shortly after the CFPB released its payday and advance deposit lending report, the FDIC and the OCC released proposed guidance warning institutions about the risks of offering deposit advance products. The guidance describes the safety and soundness, compliance and consumer protection risks posed by these products, and it encourages financial institutions “to respond to customers' small-dollar credit needs in a responsible manner and with reasonable terms and conditions.” Read the FDIC press release and OCC press release. The FRB also has released a shorter policy statement on payday and advance deposit lending that echoes the same themes as the FDIC and OCC's proposed guidance. Read the FRB press release.