Deposit Advance Products Pose No Safety and Soundness Issues

As mentioned, the OCC and FDIC have actually prefaced their proposed guidelines of deposit advance services and products on security and soundness issues. Nonetheless, there was small proof to offer the premise why these services and products pose any security and soundness dangers to your banks offering them. It is critical to note some banking institutions have actually provided deposit advance services and products for quite some time with small or no security and soundness issues, and we also are uncertain regarding the foundation for the Agencies’ concerns over institutional security and soundness. Close regulatory examination among these items has yielded fairly very good results and, notably, demonstrated that close working relationships between banking institutions and regulators may result in the growth of prudent and fair items. Continue reading