CBA thinks the approach taken by the proposed tips is flawed for a couple of reasons

CBA thinks the approach taken by the proposed tips is flawed for a couple of reasons

A bank would be required to monitor the consumer’s use of a deposit advance products and repetitive use would be viewed as evidence of weak underwriting under the proposals. To comply with the guidance, policies concerning the underwriting of deposit advance services and products needs to be written and authorized because of the bank’s board of directors and needs to be in keeping with a bank’s underwriting that is general danger appetite. Providers are likely to document a customer that is sufficient of at least six months ahead of supplying a deposit advance to your customer. The guidance would prohibit consumers with further delinquencies from eligibility. Читать далее «CBA thinks the approach taken by the proposed tips is flawed for a couple of reasons»