OCC Bulletin: Core Lending Principles for Short-Term, Small-Dollar Installment Lending

The Office of the Comptroller of the Currency (OCC) issued OCC BULLETIN 2018-14, which encourages small dollar lending by national banks. It has some interesting items regarding bank partnerships:

Reasonable policies and practices specific to short-term, small-dollar installment lending would generally include the following:

….

  • Loan pricing that complies with applicable state laws and reflects overall returns reasonably related to product risks and costs. The OCC views unfavorably an entity that partners with a bank with the sole goal of evading a lower interest rate established under the law of the entity’s licensing state(s)

OCC_ Installment Lending_ Core Lending Principles for Short-Term, Small-Dollar Installment Lending

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New York to Study FinTech Lending

In late December 2017, New York Governor Andrew Cuomo signed Senate Bill 6593, which establishes a task force regarding online lending institutions. The task force will identify the main participants in the online lending industry, how they serve consumers and small businesses and the impact of online lending activities. The task force must provide a written report to the governor on its findings and recommendations by April 15, 2018.

SB 6593: https://www.nysenate.gov/legislation/bills/2017/s6593