The American Bankers Association offers these views to the Secretary of the Treasury inrelation to the Directive that he has received under Section 2 of the Executive Order.
The demand for small dollar credit is sizeable and real. If needs are unmet by financial institutions, customers will be driven toward "informal" sources.
Banks provide a variety of small dollar credit options, including credit cards, short-term installment loans, and overdraft services, among others.
Small dollar credit supports local economic activity.
Legislation and regulation have reduced customer access to small dollar credit, with further restrictions proposed and contemplated.
The proposed/contemplated restrictions hang like a cloud over development of new small dollar credit offerings.
OCC and FDIC should withdraw their "guidance" preventing offering of Direct Deposit Advance sources of small dollar credit.
The FDIC should withdraw its overdraft "guidance."
The consumer Bureau should withdraw its proposed rule to constrain access to small dollar lending.
