OCC BULLETIN 2018-14
Subject: Installment Lending
Date: May 23, 2018
To: Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
Description: Core Lending Principles for Short-Term, Small-Dollar Installment Lending
The Office of the Comptroller of the Currency (OCC) encourages banks to offer responsible short-term, small-dollar installment loans, typically two to 12 months in duration with equal amortizing payments, to help meet the credit needs of consumers. The OCC is issuing this bulletin to remind banks1 of the core lending principles for prudently managing the risks associated with offering short-term, small-dollar installment lending programs. Banks should develop and implement these programs in a manner consistent with sound risk management practices and should align the programs with the banks’ overall business plans and strategies. Such strategies could include working with consumers who have an ability to repay a loan despite a credit profile that is outside of a bank’s typical underwriting standards for credit scores and repayment ratios. In all programs, banks should offer lending products in a manner that ensures fair access to financial services and fair treatment of consumers and complies with applicable laws and regulations. This bulletin is consistent with the OCC’s support for responsible innovation by banks to meet the evolving needs of consumers, businesses, and communities.
The OCC encourages banks to
U.S. consumers borrow nearly $90 billion every year in short-term, small-dollar loans typically ranging from $300 to $5,000.3 Many banks have withdrawn from this market, resulting in consumers often turning to alternative lenders.
Banks can provide affordable short-term, small-dollar installment lending options that can help consumers with their short-term financial needs while establishing a path to more mainstream financial products. Banks can meet consumers’ short-term, small-dollar credit needs while providing other financial services such as financial education and credit reporting. Consumers can also benefit when they are offered products with reasonable pricing and repayment structures.
In October 2017, the OCC rescinded its guidance for deposit advance products.4 Continuing the guidance would have subjected banks to potentially inconsistent regulatory direction and undue burden as they prepared to comply with the Bureau of Consumer Financial Protection’s (BCFP) final rule titled “Payday, Vehicle Title, and Certain High-Cost Installment Loans” (Payday Rule). The Payday Rule’s underwriting requirements, which have a compliance date in August 2019, generally apply to consumer loans with maturities shorter than 45 days or longer-term loans that involve balloon payments.
In January 2018, the BCFP stated that it intends to engage in a rulemaking process to reconsider the Payday Rule5 but did not indicate the specific changes that it is considering. The OCC intends to work with the BCFP and other stakeholders to ensure that OCC-supervised banks can responsibly engage in consumer lending, including lending products covered by the Payday Rule.
Core Lending Principles
Banks already offer a variety of installment lending products with maturities greater than 45 days that do not include balloon payments. The OCC believes that banks can offer these loans safely, profitably, and with reasonable pricing and repayment terms. These loans generally are not covered by the Payday Rule’s underwriting requirements.
The OCC has published three core lending principles that banks should consider when offering short-term, small-dollar installment lending products:6
Reasonable policies and practices specific to short-term, small-dollar installment lending would generally include the following:
Please contact Steven Jones, Director for Retail Credit Risk, at (202) 649-6220.
Grace E. Dailey
The following links provide more information regarding sound risk management of consumer lending activities, appropriate underwriting, and fair access and fair treatment of consumers in compliance with applicable laws and regulations.
The following links provide relevant risk management principles for new, modified, or expanded short-term, small-dollar installment lending products or products that may result in relationships with third parties.
3 Refer to Center for Financial Services Innovation, “2017 Financially Underserved Market Size Study,”
4 Refer to OCC news release 2017-118, “Acting Comptroller of the Currency Rescinds Deposit Advance Product Guidance,” October 5, 2017, announcing the rescission of OCC Bulletin 2013-40, “Deposit Advance Products: Final Supervisory Guidance.” Separately, the OCC has updated the “Installment Lending” and “Retail Lending” booklets of the Comptroller’s Handbook to add Bulletin 2018-14 and to delete Bulletin 2013-40 in the references sections.