As stated, the OCC and FDIC have actually prefaced their proposed tips of deposit advance services and products on soundness and safety issues. Nonetheless, there clearly was evidence that is little offer the premise why these services and products pose any security and soundness risks into the banking institutions that provide them. It is vital to note some banking institutions have actually provided deposit advance services and products for quite some time with small or no soundness and safety issues, so we are uncertain regarding the foundation for the AgenciesвЂ™ concerns over institutional security and soundness. Close regulatory assessment of those items has yielded reasonably very good results and, notably, demonstrated that close working relationships between banking institutions and regulators can lead to the development of wise and reasonable items. More over, as discussed below, bank-offered deposit advance items include materially less chance of injury to consumers than comparable items made available from non-depository providers.
There clearly was small proof of customer dissatisfaction with bank-offered deposit advance items. To your contrary, customer satisfaction with your services and products is frequently extremely high with below normal grievance prices. As an example, in a single bankвЂ™s current study of deposit advance customers, 90 % of participants ranked their general knowledge about the item as вЂњgoodвЂќ or вЂњexcellentвЂќ. The customer satisfaction rating ranked higher for the bankвЂ™s deposit advance product than any other product offered by that bank in another survey by a different bank. Continue reading Deposit Advance Products Pose No Safety and Soundness Concerns