Chairman Nelson, Ranking Member Collins and people in the Committee, many thanks for the opportunity to talk about the short-term liquidity needs of US customers and bank deposit advance items. I am Richard search and I also have always been President and CEO regarding the customer

Bankers Association (“CBA”). 1

Presently, a projected 76% of all of the Americans reside paycheck to paycheck. 2 The economy has remained stagnant making customers with less pillow for emergencies, strained credit scores, and less credit choices, making usage of fairly priced short-term liquidity items all that more important. Different entry-level credit services and products occur to fulfill a number of requirements, including traditional charge cards, unsecured loans, as well as other types of credit. Regrettably, numerous customers usually do not be eligible for them. Responding, some banking institutions have actually opted for to provide a deposit advance product to meet up their clients’ need and interest in short-term, small-dollar credit. 3

Deposit advance items, offered today by just six banks, provide a critical short-term, smalldollar credit interest in customers that do maybe maybe perhaps not be eligible for old-fashioned credit services and products. The products aren’t loans, these are generally credit lines (“LOC”) paid back immediately from a recurring direct deposit. While specific items differ, the absolute most advanced level is limited by the smaller of the cap (typically $500) or a portion regarding the average paymagent that is recurringe.g. 50 %). Deposit advances providers often charge an obvious, easily comprehended cost according to a portion for the loan.

Executive Overview

  • Deposit advance items are small-dollar personal lines of credit available and then bank clients with established checking account relationships in good standing. They’re not loans that are payday. These items include features such as for example maximum loan size and cool down durations to guard customers from reliance from the item.
  • There clearly was high customer interest in viable short-term, little buck credit. Deposit advance items are made to properly, quickly and conveniently satisfy this need. customers realize and like bank deposit advance items. These items have obtained customer that is positive and carry few complaints.
  • Deposit advance services and products would not have a disparate effect on seniors. Total client use corresponds approximately utilizing the populace of seniors in the usa.
  • Deposit advance services and products have now been provided by depository organizations for several years and therefore are intensely controlled for customer security and security and soundness issues. The potential risks to customers and supervised institutions recently cited by federal prudential regulators are overstated and regulatory coordination is highly advised going ahead. Deposit advance items usually do not provide soundness and safety dangers into the organizations offering them. These items have actually integrated settings to limit usage, aren’t earnestly marketed, and gives clear and disclosures that are conspicuous.

In testimony before a home Subcommittee, Senator Elizabeth Warren, then Unique Advisor towards the Secretary of this Treasury when it comes to customer Financial Protection Bureau (“CFPB”), said,

“consumers need to know the expenses up-front and don’t desire to be blindsided by concealed charges, rate of interest modifications, or re payment shocks. Informed decision-making allows customers to operate a vehicle the financial market to ensure that providers offer items that meet customer requirements and preferences.” 4 As outlined inside our testimony today, CBA thinks the banking institutions providing deposit advance services and products have actually followed to these terms within the strictest feeling by giving reasonably priced items with extremely clear terms, fulfilling the need of U.S. customers.


Deposit advance items are greatly managed and very very carefully made to guarantee strong customer safeguards at reasonable rates. especially, deposit advance items have actually properly offered customer interest in a long time under intense scrutiny that is regulatory one item having held it’s place in presence for almost 2 full decades. As a result, the products have already been scrutinized repeatedly for customer security and security and soundness issues by many state and federal banking regulators. Banking institutions have actually answered by working together with regulators to make sure items that would be best suited for public providing.

Bank-offered deposit advance services and products provide an essential function: they help in keeping customers from being pressed from the heavily regulated bank system and into higher priced and often less and inconsistently regulated options such as for instance conventional payday advances, pawn brokers, name loans as well as other resources of short-term, small-dollar financing. also, without reasonable options, customers can pay greater charges for short-term liquidity or may face increased delinquency, belated re re re payment, nonsufficient investment, and payday loans New Jersey returned check charges.

Among the benefits of bank-offered deposit advance items is they’ve been typically cheaper than many other options. The average cost of a payday loan is $15.26, some of course are much higher for example, for a $100 loan repaid over a 30 day period. 5 also during the greatest end, the price of a bank deposit advance item for similar quantity is just $10, with some as little as $7.50.

More providers available on the market and efficient and regulation that is consistent make sure greater competition and innovation, which eventually increases defenses and reduced expenses. Extremely

prescriptive restrictions on bank-offered deposit advance services and products will result in less competition and a rise in rates 5 – one thing perhaps perhaps perhaps maybe not into the desires of customers.

Customer need is obvious: Bank clients consistently enroll high satisfaction prices for deposit advance services and products. At an industry hearing held by the CFPB on January 19, 2012 in

Birmingham, Alabama, Director Richard Cordray remarked, “I want to be clear about something:

We observe that there is certainly a necessity and a need in this nation for crisis credit.” 6 This declaration rings more today that is true ever. Customers demand access to short-term, small-dollar options, frequently with the solution as a cashflow administration device. They appreciate the product’s convenience whenever in conjunction with a deposit account and recognize the worth in using services provided by their bank of preference. Customers talk really very of this item, registering testimonials like “I’m extremely thankful for deposit advance… This has assisted me personally through some rough times… I hope this survey doesn’t suggest they have been considering closing this system,” and “deposit advance has made my entire life plenty easier…there have now been many times where i’ve discovered myself in a bind, but managed to make ends meet because of deposit advance.”

In ’09, Professor Todd Zywicki of George Mason University published a paper handling the drawbacks customers will experience should extremely restrictive bans be placed on payday lending. 7 In their report, Zywicki writes, “consumers usage payday lending to cope with short-term exigencies and deficiencies in usage of payday advances may likely cause them significant price and private trouble, such as bounced checks, disconnected utilities, or not enough funds for emergencies such as for example medical costs or vehicle repairs. As a result, having banks compete in this room will provide to profit the buyer by better serving their short-term liquidity requires.”

Crippling the capability of banks to supply deposit advance services and products will likely not re re solve the underlining problem that produces the necessity for them, and customer need shall not reduce. CBA urges lawmakers and regulators to offer strong consideration to the feasible unintended unfavorable effects on customers whenever considering actions that will impact or get rid of the cap cap ability of banks to supply deposit advance services and products. There was acknowledgement that is significant banking regulators and advocacy categories of the marketplace need and a necessity for short-term, little buck financial products.