Although few banks offer tax refund-related credit and deposit products, the OCC yesterday issued guidance for managing risks associated with these tax refund products. The guidance applies to banks that offer loans based on anticipated refunds and prepaid cards in lieu of cash refunds, among other products.
The guidance covers risk management topics including governance, internal controls, disclosures, third-party risk, Bank Secrecy Act compliance, consumer protections, training, capital and liquidity.