- BofA's no-action letter from the CFPB will minimize regulatory scrutiny of its forthcoming small-dollar loan program.
- This illustrates how banks can benefit from carrying out financial regulators' directives amid the pandemic.
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The Consumer Financial Protection Bureau (CFPB) approval means that the bank is unlikely to see supervisory or enforcement action from the bureau for its new small-dollar loan offering, dubbed Balance Assist, American Banker reports.
Announced last month and beginning in January, Bank of America (BofA) will offer loans of $100–$500 that carry a flat $5 fee and must be repaid in equal installments over 90 days. The loans will be available to customers who have had a checking account with the bank for at least a year. Balance Assist follows a regulatory recommendation from May that major banks provide responsible small-dollar loans in response to the pandemic, as an alternative to often predatory payday lenders.
BofA's no-action letter is an example of the benefits banks can reap by stepping up to the requests put forth by financial regulators. We have maintained since the beginning of the coronavirus pandemic that by impressing regulatory bodies with their relief offerings, banks could minimize scrutiny from those regulators.
That hypothesis is borne out in BofA's no-action letter, as the bank will be able to operate its small-dollar loan offering without having to worry about a CFPB crackdown. And because BofA is the first major bank to receive approval for this kind of program, it may win additional favor among regulators for ramping up so quickly.
The good news from the CFPB comes on the heels of improvements BofA is making to its Erica virtual assistant. The bank is revamping internal systems and developing APIs that will facilitate a seamless hand-off between Erica and live chat operated by human customer service agents, Bank Innovation reports.
These improvements could smooth the transition from virtual to human assistance for customers whose requests can't be fulfilled by Erica alone—likely reducing frustration among users. The upgrade aligns with other changes amid the pandemic and spiking Erica usage: It hit 15.9 million in Q3 2020, up from 14.4 million in Q2.
Pandemic-specific updates include training the assistant to recognize 60,000 pandemic-related terms and inquiries, and upgrading Erica with the ability to provide information on Merrill Lynch portfolio balances and trading activity. Between the Balance Assist program and Erica's strong capabilities, BofA's customer support as the pandemic drags on is going to stand out as particularly robust.
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