In a comment letter dated January 19, 2019, the Community Bankers Association of Illinois (CBAI) responded to the Federal Deposit Insurance Corporation (FDIC) request for information (RFI) on small-dollar lending. CBAI highlighted challenges in this area that included: the increased costs of loan origination, underwriting, funding and administration; barriers to charging sufficient interest rates and fees; and higher loan charge-offs. CBAI stressed that the understanding and cooperation of the FDIC will be required, particularly regarding the differences in underwriting and loan features between community banks and other lenders, and the important role “character” plays in community bank lending decisions. Flexibility will be needed both on the part of the FDIC and community banks to encourage an expansion of small-dollar consumer lending. Read CBAI’s Comment Letter.