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Small Dollar Loans and In-School Branching as Entry Points for Reaching Underserved Markets . James P. Maloney Chairman, Mitchell Bank. Small Dollar Loan Pilot. Nature of FDIC Pilot FDIC Guidelines issued June 19, 2007– everything you need to know.
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Small Dollar Loans and In-School Branching as Entry Points for Reaching Underserved Markets James P. Maloney Chairman, Mitchell Bank Advisory Committee Meeting on Economic Inclusion
Small Dollar Loan Pilot • Nature of FDIC Pilot • FDIC Guidelines issued June 19, 2007– everything you need to know. • www.fdic.gov/news/news/press/2007/pr07052a.html; Bair, Low-Cost Payday Loans; www.aecf.org • Why encouraged by FDIC • Why banks would want to do it. Advisory Committee Meeting on Economic Inclusion
Common Features of SDLs • Fully Amortizing Term Loan- $300 to $1000 • Breaking the Cycle of Multiple Renewals and Rollovers • Not to be fee-based overdraft or bounce protection • Streamlined Underwriting, Processing and Decision Making • Traditional Credit Scoring vs. Payday Lender Data; No credit score/thin file • Savings Component and “suitability” Advisory Committee Meeting on Economic Inclusion
Regulatory Issues and CRA • State Consumer Protection Laws/Reg Z and TILA • Subprime Interagency Guidance/FDIC • CRA consideration and promise Advisory Committee Meeting on Economic Inclusion
Cardinal Bank/ A Sustained Initiative • Introduced in 2000 and now 8 years old • Branch operated by 8 to 10 senior students—8 separate classes • Overcoming trust issues and teaching financial literacy • Over 800 new accounts for unbanked families • Increase of community based accounts in Main Bank Advisory Committee Meeting on Economic Inclusion
CARDINAL BANK • Background of start up • Demonstrates importance of partnerships within community • Formal branch application to FDIC and State regulators. • Full service branch vs. “school” sub accounts • Students are our “Ambassadors” to community Advisory Committee Meeting on Economic Inclusion
CARDINAL BANK • Real accounts because we are targeting students and their parents • Bank presence--officers of bank, not just teachers • Separate Board of Directors/Officers of bank • Students market bank to peers/ Classroom presentations Advisory Committee Meeting on Economic Inclusion
Cardinal Bank • New Expansion to formal Finance Class within School curriculum • Students have become the family financial advisors • Student Bankers teaching at elementary schools • Employment of student bankers after graduation Advisory Committee Meeting on Economic Inclusion