FDIC RFI on Small Dollar Lending

On January 22, 2019, OLA provided comments to the FDIC in response to an Agency RFI on increasing small dollar lending by FDIC regulated institutions. The focus of OLA comments covered the following topics:

• Bank fintech partnerships and the need to address current legal impediments
• Impact that a 36% interest rate cap will have
• Need for FDIC to revise its 2007 Small Dollar Loan Guidance that “encourage lenders to offer small-dollar credit with APRs no greater than 36 percent” 
• Impact that the failure to fully address Operation Choke Point has had on small dollar lending.