A bank would be required to monitor the consumer’s use of a deposit advance products and repetitive use would be viewed as evidence of weak underwriting under the proposals. To conform to the guidance, policies concerning the underwriting of deposit advance services and products must certanly be written and authorized because of the bank’s board of directors and must certanly be in keeping with a bank’s underwriting that is general risk appetite. Providers will also be likely to document a customer that is sufficient of at least 6 months just before supplying a deposit advance to your customer. The guidance would further prohibit customers with delinquencies from eligibility.
The lender additionally needs to analyze the customer’s capacity that is financial these items, including income amounts and deposit inflows and outflows along with using conventional underwriting requirements to find out eligibility.
