As stated, the OCC and FDIC have actually prefaced their proposed tips of deposit advance services and products on security and soundness concerns. Nonetheless, there was evidence that is little offer the premise why these items pose any security and soundness dangers to your banking institutions that provide them. You will need to note some banking institutions have actually provided deposit advance items for several years with small or no security and soundness issues, therefore we are uncertain regarding the foundation for the Agencies’ concerns over institutional security and soundness. Close examination that is regulatory of services and products has yielded reasonably excellent results and, significantly, demonstrated that close working relationships between banking institutions and regulators may result in the introduction of wise and reasonable services and products. More over, as discussed below, bank-offered deposit advance items include materially less threat of problems for customers than comparable services and products provided by non-depository providers.

Reputational Danger

There was small proof consumer dissatisfaction with bank-offered deposit advance services and products. To your contrary, customer satisfaction with one of these services and products is usually quite high with below normal grievance prices. For instance, in a single bank’s current survey of deposit advance clients, 90 % of participants ranked their general knowledge about the item as “good” or “excellent”.

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