A bank would be required to monitor the consumerвЂ™s use of a deposit advance products and repetitive use would be viewed as evidence of weak underwriting under the proposals. To conform to the guidance, policies regarding the underwriting of deposit advance items should be written and authorized because of the bankвЂ™s board of directors and must certanly be in line with a bankвЂ™s underwriting that is general danger appetite. Providers may also be likely to document a customer that is sufficient of at least half a year ahead of supplying a deposit advance into the consumer. The guidance would further prohibit customers with delinquencies from eligibility.
The lender also needs to analyze the customerвЂ™s monetary ability with the products, including earnings amounts and deposit inflows and outflows as well as using old-fashioned underwriting requirements to find out eligibility.