Further comment on payday lending and deposit advances

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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. These agencies have all signaled a willingness to prohibit these loans without regard to Dodd-Frank’s definitions of the terms “unfair” and “abusive” and without applying the cost-benefit analysis required by the statutory language. My concerns are articulated in some detail in a comment letter I submitted to the OCC and FDIC yesterday on my own initiative. The apparent regulatory approach— which involves the substitution of visceral reactions in place of rigorous analysis—has disturbing implications that go well beyond the impact on payday loans and deposit advances.