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Product Update Blog

Product Updates August 2020

Product Updates for August 2020

The Product Updates for August 2020 from BankPolicies.com feature the following revised policy template products:

Consumer Loan Policy Template

Payday, Vehicle Title, and High-Cost Installment Loan Policy Template

The update to these products is in response to the CFPB’s Press Release entitled “Consumer Financial Protection Bureau Issues Final Rule on Small Dollar Lending” dated 07/07/20 that issued a final rule concerning small dollar lending in order to maintain consumer access to credit and competition in the marketplace.  The final rule rescinds the mandatory underwriting provisions of the 2017 rule after re-evaluating the legal and evidentiary bases for these provisions and finding them to be insufficient.  The final rule does not rescind or alter the payments provisions of the 2017 rule.  The final rule if effective October 20, 2020.

As a reminder, the complete contents of the Payday, Vehicle Title, and High-Cost Installment Loan Policy Template are included within the Consumer Loan Policy Template as Topic 16.

Marketing Plan and Program Policy Template

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Template

Unfair or Deceptive Acts or Practices (UDAP) Policy Template

The update to these products is in response to the OCC’s Bulletin 2020-65 entitled “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices: New Comptroller’s Handbook Booklet and Recissions” dated 06/29/20 that announced a new “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook.  The booklet contains information regarding supervision of a bank’s practices related to section 5 of the Federal Trade Commission (FTC) Act, which prohibits banks from engaging in unfair or deceptive acts or practices (UDAP), and sections 1031 and 1036 of the Dodd–Frank Wall Street Reform and Consumer Protection Act, which prohibit unfair, deceptive, or abusive acts or practices (UDAAP).  The bulleting also rescinds:

  • Office of Thrift Supervision Examination Handbook, section 1354, “Unfair or Deceptive Acts or Practices, Federal Trade Commission Act, Section 5.”
  • Office of Thrift Supervision Examination Handbook, section 1355, “Unfair or Deceptive Acts or Practices – Credit Practices Rule.”

Regulation O and Insider Activity Policy Template

The update to this product is in response to the Federal Reserve’s interim final rule dated 07/15/20 to except certain loans made by June 30, 2020, that are guaranteed under the Small Business Administration’s Paycheck Protection Program from the requirements of the Federal Reserve Act and the corresponding provisions of the Federal Reserve Board’s Regulation O.  This interim final rule to expand the exception to apply to PPP loans made through August 8, 2020, and is effective July 16, 2020.

Keeping You Informed

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