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#2216855 - 07/02/19 12:08 AM Small Dollar Consumer Loans
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,097
Do small dollar consumer loans qualify under the service test?

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CRA
#2216862 - 07/02/19 12:54 PM Re: Small Dollar Consumer Loans Mel in WA
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 762
Yes - Helps meet the credit needs of those in the community and offers an alternative to high cost PayDay or Title lenders.

See this recent FIL. https://www.fdic.gov/news/news/financial/2018/fil18071.html

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#2217165 - 07/08/19 07:37 PM Re: Small Dollar Consumer Loans Mel in WA
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
It's important to note in addition to Tennismom if you are regulated by the FRB they don't currently have any guidance, or go ahead around small dollar lending. In their papers they note that they recognize the community benefit, but that's not an official stance.

Or if you are OCC regulated here is their go ahead: https://www.occ.treas.gov/news-issuances/bulletins/2018/bulletin-2018-14.html

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