TOPIC: Ability To Pay

Banks and Credit Unions: Break Down Your Data Silos to Build Up Your Revenue!

When your account holder data is spread across disparate systems in multiple lines of business, every aspect of your organization’s performance is impeded from acquisition to onboarding to retention – meaning that your institution has likely missed critical service and marketing opportunities in your account holders’ journeys.
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    Small Loans and Ability to Repay

    CEO at a bank ($38MUSA)
    I'm in a micro bank in a town without payday lenders or finance companies and have always considered it the bank's responsibility to fund those small loans.  Sometimes as low as $50.00.  I just charge the maximum allowed and it may only be $2.00 as the APY can only be 21%.  

    If anyone has a policy that covers these type loans I'd like to see and the justification for Examiners.  Do you have ATR requirements?  I deduct 28% of income for Housing (even though  roommate pays 100%) and 14% for monthly payment expense. Total is 42% and rest is for living expense. So basically if their existing and new payment are more than 14% of income I would need to bend policy if loan is made. 

    My bend is justified by my thoughts that about anyone will repay a $2,000 unsecured loan. 

    Any of your thoughts or policy considerations will be appreciated.