Finally, the PALs II NPRM proposed to get rid of the restriction regarding the wide range of PALs II loans that an FCU will make to an individual debtor in a rolling 6-month duration. The PALs I rule presently forbids an FCU from making significantly more than three PALs loans in a rolling 6-month duration up to a solitary borrower. 24 An FCU additionally might not make a lot more than one PALs I loan to a debtor at any given time. The Board proposed getting rid of the rolling 6-month requirement of PALs II loans to give FCU’s with maximum flexibility to satisfy debtor need. Nevertheless, the PALs II NPRM proposed to hold the necessity through the PALs I rule that an FCU can simply make one loan at a right time to virtually any one debtor. Appropriately, the PALs II NPRM failed to enable an FCU to produce a lot more than one PALs item, whether a PALs I or PALs II loan, to a solitary borrower at a given time.
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The PALs II NPRM asked general questions about PAL loans, including whether the Board should prohibit an FCU from charging overdraft fees for any PAL loan payments drawn against a member’s account in addition to the proposed PALs II framework. The PALs II NPRM additionally asked concerns, into the nature of an ANPR, about whether or not the Board should produce a extra type of pal loan, described as PALs III, which may be more versatile than just just what the Board proposed when you look at the PALs II NPRM. Before proposing a PALs III loan, the PALs II NPRM desired to evaluate industry need for such something, along with solicit touch upon just what features and loan structures should really be contained in a PALs III loan.
Summary of commentary in the PALs II NPRM
The Board received 54 responses regarding the PALs II NPRM from 5 credit union trade businesses, 17 state credit union leagues, 5 customer advocacy teams, 2 state and governments that are local 2 charitable businesses, 2 academics, 2 solicitors, 3 credit union solution companies, 14 credit unions, and 2 individuals.