CBA Joint Comment to OCC on Deposit Advance Product Proposed Guidance

Dear Sir or Madam:
This comment letter is submitted by the Consumer Bankers Association, The Financial Services Roundtable,  and The Clearing House (collectively the “Associations”) in response to proposed supervisory guidance (“Proposal”) regarding deposit advance products, which was published in the Federal Register on April 30, 2013, by the Office of the Comptroller of the Currency (“OCC” or “Agency”). The Associations strongly support effective consumer protections and, specifically, the principles of choice, transparency and fairness in customer relationships. We appreciate the opportunity to share our suggestions and work with the OCC, and others, as it considers the issues related to deposit advance products.
The OCC is proposing to clarify the application of safe and sound banking practices and consumer protection in connection with bank-offered deposit advance products. The Proposal details the principles the OCC expects its supervised financial institutions to follow in connection with deposit advance products in order to manage the reputational, compliance, legal and credit risks, which the OCC perceives to be associated with these products. Specifically, the guidance seeks to address a number of issues, including eligibility standards, disclosures, product limitations, monitoring and risk assessments, and management oversight. The Proposal includes a withdrawal of the OCC’s previously proposed guidance on Deposit-Related Products published on June 8, 2011.

To read the full Comment Letter, download the PDF.