These examination procedures apply to the short-term, small-dollar credit market, commonly known as payday lending.
The procedures are comprised of modules covering a payday loan’s lifecycle, and each module identifies relevant matters for review. Prior to using the procedures, however, examiners should complete a risk assessment and examination scope memorandum. Depending on the scope, and in conjunction with the compliance management system and consumer complaint response review procedures, each examination will cover one or more of the following modules:
- Application and Origination
- Payment Processing and Sustained Use
- Collections, Accounts in Default, and Consumer Reporting
- Service Provider Relationships