BPI Responds To the FDIC’s Request for Information on Small-Dollar Lending

On January 22, the Bank Policy Institute submitted a comment letter to the Federal Deposit Insurance Corporation (FDIC) on its request for information seeking input regarding small-dollar credit products.

BPI’s letter sets forth and discusses three key principles:

  • Any regulatory requirements or guidance should serve the broader goal of encouraging responsible, innovative lending by banks to their customers by streamlining, rather than adding to, existing supervisory expectations for such products and allowing for increased regulatory coordination.
  • Any guidance for small-dollar credit practices primarily should focus on existing risk management or other internal safety and soundness standards for lending and banks’ own internal systems and practices for meeting them, rather than creating a separate distinct and incremental set of supervisory expectations applicable only to small-dollar lending.
  • Any additional regulatory requirements or expectations for small-dollar lending by banks should avoid imposing unnecessary burdens that would limit banks’ ability to provide small-dollar credit products, and thus customers’ ability to obtain such products.