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Comments to OCC and FDIC Deposit Advance Proposed Guidance -- Opponents Outnumber Proponents



by Justin Angelo
Greenberg Traurig, LLP - Fort Lauderdale Office

Robert E. Bostrom
Greenberg Traurig, LLP - New York Office

Thomas J. McKee
Greenberg Traurig, LLP - McLean Office

Gil Rudolph
Greenberg Traurig, LLP - McLean Office

J. Scott Sheehan
Greenberg Traurig, LLP - Houston Office

July 18, 2013

Previously published on July 16, 2013

The Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) each published a proposed guidance on deposit advance products on April 30th, 2013. Deposit advance products are small dollar, short-term loans offered by a bank to its deposit account customers with recurring deposits. Deposit advance products typically have high fees and are repaid from the funds of the next direct deposit, similar to payday loans. The proposed guidance seeks to clarify the agencies’ interpretation of “safety and soundness” and consumer protection principles as applied to deposit advance products. Both agencies requested comments on their proposed guidance.


 

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