Trillium's Statement in Support of FDIC and OCC Guidance on Deposit Advance Products
Trillium Asset Management, LLC commends the FDIC and OCC for issuing its final supervisory guidance on deposit advance products. As an investor in banks that offer or may offer these products we agree with the FDIC and OCC that it is important for banks to incorporate fully and comprehensively the credit, reputational, operational, and compliance risks that these products present.
While small-dollar credit products are useful and necessary for consumers, banks have a financial and social responsibility to ensure they are offered in a sound manner. We believe that responsible lending practices that strengthen rather than weaken customers’ financial health are in the best interest of banks, clients, shareholders, and the wider economy and call upon all banks to swiftly implement the guidelines for responsible small loans articulated by the OCC and FDIC.