FDIC Clarifies 2005 Payday Lending Guidance

The FDIC clarified its "Payday Lending Programs: Revised Examination Guidance" and the attached "Revised Guidelines for Payday Lending" (collectively, the "2005 Payday Lending Guidance") to "ensure that bankers and others are aware that [the 2005 Payday Lending Guidance] does not apply to banks offering products and services, such as deposit accounts and extensions of credit, to non-bank payday lenders."

The FDIC specified that the Financial Institution Letter applies to all FDIC-supervised financial institutions that make payday loans.