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The CFPB Issues No-Action Letter for Small-Dollar Short-Term Credit Product

  • The Consumer Financial Protection Bureau (“CFPB”) issued a no-action letter (“NAL”) to Bank of America, N.A. regarding its “Balance Assist” credit product designed to provide a banking solution to consumers with short-term liquidity needs.
  • The NAL was issued pursuant to the updated NAL policy, and is meant to increase regulatory certainty that the CFPB will not bring supervisory or enforcement action against the bank under the circumstances detailed in the letter.
  • Bank of America’s application for the NAL was based on CFPB’s application template, which provides guidance on the information and certifications that an application for a NAL should include and the scope of a potential NAL issued in response to an application.