Thanks Mary. This article is not only a great analysis of the problem, but reminds bankers who think the rate cap will never affect them that they ought to think again because it's possible examiners "may want scenarios to be run assuming the rate cap is in force, and if those scenarios aren't pretty, it could be further grounds for criticism."
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Barb Rehm
Senior Managing Director
Promontory Interfinancial Network
Arlington VA
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Original Message:
Sent: 11-14-2018 12:19
From: Mary Fowler
Subject: Rate cap rules threaten efforts to serve the underbanked
Our CFO (who is also my son) wrote this article which went up on BankThink today:
https://www.americanbanker.com/opinion/fdics-rate-caps-threaten-efforts-to-serve-the-underbanked
The rate cap rule has a disparate impact on the customers of banks who serve a net-borrower customer base. Many times these banks, like ours, serve the underbanked, low income, middle income, minority, and ethnic populations. Economic inclusion is being restricted by outdated rules.
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