Compliance issues related to payday lending are all of the following EXCEPT:
Posted: Tue Mar 08, 2022 9:34 am
Compliance issues related to payday lending are all of the following EXCEPT:
A. Payday lending may adversely affect a bank"™s CRA rating. Any illegal or questionable practices will negatively affect a bank"™s CRA performance. A payday lending program may be inconsistent with helping to meet the community"™s credit needs
B. The bank (or its third-party partner) must properly disclose all finance charges and fees to payday lending customers. Advertisements of the program are also subject to Truth-in-Lending requirements
C. Adverse action disclosures must be provided to applicants of payday loans that are denied if a consumer report (including check tracking services) was used in the credit decision
D. The bank may be subject to the FOC"™s unfair or deceptive practices rules.
A. Payday lending may adversely affect a bank"™s CRA rating. Any illegal or questionable practices will negatively affect a bank"™s CRA performance. A payday lending program may be inconsistent with helping to meet the community"™s credit needs
B. The bank (or its third-party partner) must properly disclose all finance charges and fees to payday lending customers. Advertisements of the program are also subject to Truth-in-Lending requirements
C. Adverse action disclosures must be provided to applicants of payday loans that are denied if a consumer report (including check tracking services) was used in the credit decision
D. The bank may be subject to the FOC"™s unfair or deceptive practices rules.