Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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CFPB releases more overdraft program data as a prelude to likely rulemaking

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

8/4/2014 - Banks CFPB Checking Accounts FDIC Information Reports OCC Overdraft Fees Regulation E Rulemaking Process

‘Operation Choke Point’ under Fire

"Operation Choke Point," the coordinated multiagency federal effort to choke off banking services to alleged fraudsters (according to its defenders) or politically unpopular industries (according to its detractors), has come...more

6/13/2014 - ACH Payments Administrative Procedure Act Banks CFPB Choke Point Community Financial Services Association DOJ FDIC Fraud OCC Payday Loans

OCC and FDIC Follow Through on Threat To Kill Deposit Advance Loans

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more

12/2/2013 - Banks Deposit Advances FDIC Loans OCC

Elizabeth Warren and Bill Nelson support OCC and FDIC on deposit advances

A friend brought to my attention a two-page comment letter from Senators Elizabeth Warren and Bill Nelson, commenting on the OCC’s proposed deposit advance guidance, the subject of a prior blog....more

7/1/2013 - CFPB Deposit Advances Elizabeth Warren FDIC OCC Public Benefits TILA

A bit of balance from a consumer advocate

Jeff Sovern and I come at most issues from different sides of the street but I want to credit him for the open mind he showed in his recent blog post on deposit advance loans....more

6/26/2013 - Borrowers CFPB Deposit Advances FDIC OCC Payday Loans

Further comment on payday lending and deposit advances

As suggested by prior blog posts, I am no fan of the direction the CFPB, OCC and FDIC seem to be going with respect to payday and deposit advance loans. ...more

5/31/2013 - CFPB Deposit Advances FDIC OCC Payday Loans

OCC and FDIC proposed guidance could effectively ban deposit advance loans

Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more

4/30/2013 - CFPB Compliance Deposit Advances FDIC Loans OCC Proposed Regulation Underwriting

The shoes are dropping: CFPB study of payday and deposit advance loans precedes reported OCC/FDIC action against deposit advance...

Earlier today, the CFPB released a white paper reporting on its study of 15,000,000 storefront payday loans and 100,000 accounts eligible for deposit advances (of which approximately 15% involved a deposit advance during the...more

4/25/2013 - CFPB Deposit Advances FDIC OCC Payday Loans

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