Banks, Credit Unions and Payday Lending Examinations and Investigations

    View Authors July 2012

    Banks, credit unions and other consumer lenders that offer short-term loans and financial products (or payday-like loans) should take notice. The Financial Deposit Insurance Corporation (FDIC), the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) are working together along with other federal agencies to examine payday lending practices, including such practices conducted by banks and credit unions.

    This publication is a brief discussion of the challenges banks and credit unions may face under heightened scrutiny by the CFPB and FDIC and steps to take in anticipation of a CFPB examination and any subsequent investigations. So far, the CFPB has focused on non-bank payday lenders in its attempt to fairly regulate “both banks and the nonbank firms that directly compete against one another in many of the same markets.”  But the CFPB is clear that consumer products provided by banks and credit unions will receive the same scrutiny.