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During the past year, the Consumer Financial Protection Bureau
(CFPB) has engaged in an in-depth review of short-term small dollar
loans, specifically payday loans extended by non-depository
institutions and deposit advance products offered by a small, but
growing, number of depository institutions to their deposit account
customers. This review began with a field hearing held in
Birmingham, Alabama in January 2012. At that event, CFPB Director
Richard Cordray noted that "the purpose of the field hearing, and
the purpose of all our research and analysis and outreach on these
issues, is to help us figure out how to determine the right
approach to protect consumers and ensure that they have access to a
small loan market that is fair, transparent, and competitive."
Director Cordray went on to state that "through forums like this
and through our supervision program, we will systematically gather
data to get a complete picture of the payday market and its impact
on consumers," including how consumers "are affected by long-term
use of these products."
In February 2012, the Consumer Financial Protection Bureau (CFPB)
initiated a broad inquiry into financial institutions' overdraft
programs for consumer checking accounts. This effort included a
public Request for Information (RFI) and a detailed study of
overdraft programs at a small set of large banks that are
supervised by the CFPB. These banks provide a significant portion
of all U.S. consumer checking accounts. Through the CFPB's
supervision program, these banks have provided institution-level
information about their overdraft programs and accounts during 2010
and 2011. Many of the concerns that motivated the CFPB's inquiry
are not new. In response to growing costs to consumers, federal
agencies have addressed these issues in different ways at different
times, which industry has recognized.a Our review is intended to
provide the factual basis to inform efforts to develop more uniform
treatment of these issues across financial institutions.
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