Compliance Issues Related to Payday Lending Are All of the Following

Compliance issues related to payday lending are all of the following EXCEPT:

A) Payday lending may adversely affect a bank's CRA rating. Any illegal or questionable practices will negatively affect a bank's CRA performance. A payday lending program may be inconsistent with helping to meet the community's credit needs
B) The bank (or its third-party partner) must properly disclose all finance charges and fees to payday lending customers. Advertisements of the program are also subject to Truth-in-Lending requirements
C) Adverse action disclosures must be provided to applicants of payday loans that are denied if a consumer report (including check tracking services) was used in the credit decision
D) The bank may be subject to the FOC's unfair or deceptive practices rules.