b'CFPB Issues No-Action Letter on Bank of America Small-Dollar Credit ProductsIn May, the CFPB announced a template that banks and credit unions within its jurisdiction can use to apply for NALs covering their small-dollar loan products. Inaccordance with this policy, the CFPB granted a NAL to Bank of America, N.A. regarding its then-proposed small-dollar credit product, Balance Assist, which provides the Banks checking account customers access to credit in increments of $100, up to $500, to be repaid in fixed minimum payments over three months, for a flat $5 Product Fee. The NAL issued to Bank of America provides increased regulatory certainty that the CFPB will not bring a supervisory or enforcement action under the facts and circumstances provided for in Bank of Americas NAL application. TheNAL remains in effect until terminated by the CFPB. Looking Ahead to 2021In 2021, we anticipate that regulators and policymakers will focus on balancing the need to provide avenues through which consumers impacted by the pandemic can secure short-term liquidity against the sentiment of some Democrats and consumer protection advocates that payday lending should be regulated into oblivion. Ata minimum, we expect that the CFPB will be aggressive in launching investigations and initiating enforcement actions in the payday lending space as a stop-gap measure until a more comprehensive suite of legislative or regulatory actions can be taken. In the long term, the industry should prepare for the Biden administration to support efforts to reform the industry, including through requiring additional loan disclosures, setting interest rate caps, and attempting to revive the now-rescinded ability to repay underwriting provisions of the Payday Lending Rule. Efforts to restore the original Payday Lending Rule are likely to be on the agenda of a Chopra-led CFPB, though such efforts may be tempered or postponed in light of the realities of the pandemic. What to Watch Challenges to the OCCs True Lender Rule.Periodic guidance from the CFPB on Fintech alternatives to traditional payday lending.Legislative/regulatory proposals and court challenges aimed at resurrecting the Cordray-Era Payday Lending Rule.38'