Banks for PDL and Small Dollar CreditLenders
Published: Wed, 01/28/15
Some great news for those of us in need of a bank:
[Note: The official "Letter" is attached to this email
as a PDF.]
Financial Institution Letter
FIL-5-2015
January 28, 2015
Statement on Providing Banking Services
[Read Online and get the Official Letter:]
http://paydayloanindustryblog.com/?p=3085
The FDIC encourages insured depository institutions to serve their
communities and recognizes the importance of the services they
provide. Individual customers within broader customer categories
present varying degrees of risk. Accordingly, the FDIC encourages
institutions to take a risk-based approach in assessing individual
customer relationships rather than declining to provide banking
services to entire categories of customers, without regard to the
risks presented by an individual customer or the financial
institution's ability to manage the risk. Financial institutions
that can properly manage customer relationships and effectively
mitigate risks are neither prohibited nor discouraged from
providing services to any category of customer accounts or
individual customer operating in compliance with applicable state
and federal law.
The FDIC is aware that some institutions may be hesitant to provide
certain types of banking services due to concerns that they will be
unable to comply with the associated requirements of the Bank
Secrecy Act (BSA). The FDIC and the other federal banking agencies
recognize that as a practical matter, it is not possible for a
financial institution to detect and report all potentially illicit
transactions that flow through an institution.1 Isolated or
technical violations, which are limited instances of noncompliance
with the BSA that occur within an otherwise adequate
system of policies, procedures, and processes, generally do not
prompt serious regulatory concern or reflect negatively on
management's supervision or commitment to BSA compliance. When an
institution follows existing guidance and establishes and maintains
an appropriate risk- based program, the institution will be
well-positioned to appropriately manage customer
accounts, while generally detecting and deterring illicit financial
transactions.
Any FDIC-supervised institution concerned that FDIC personnel are
not following the policies laid out in this statement may contact
the FDIC's Office of the Ombudsman (OO) at the following dedicated
toll-free number, 1-800-756-8854, or dedicated email address,
bankingservicesOO@fdic.gov. Communications with the OO are
confidential. The FDIC also
has an independent Office of Inspector General (OIG) that is
charged with addressing allegations of waste, fraud, and abuse
related to the programs and operations of the FDIC. Individuals or
institutions may contact the FDIC OIG through its Web site at
www.fdicoig.gov by using the "Hotline" button, by phone at
1-800-864-3342, or by email at ighotline@fdic.gov.
Doreen R. Eberley
Director
Division of Risk Management Supervision