Proposal for OCC to charter “Federal Financial Services and Credit Companies” draws ire from consumer advocate


[author: ]

A bill introduced in Congress that would provide for the OCC to charter and regulate “Federal Financial Services and Credit Companies” (FFSCCs) was recently called a “get out of regulation free card” in a blog post by Ed Mierzwinski, U.S. PIRG’s Consumer Program Director.   

H.R. 1909, titled “FFSCC Charter Act of 2011″ and introduced in May 2011, would allow a company to qualify as an FFSCC if it satisfies certain requirements that include having “a demonstrated history of experience in providing underbanked persons” with a financial product within one of the following services: (1) extending credit to consumers in any amount or to small businesses in amounts less than $10,000, (2) issuing reloadable stored value cards to consumers or small businesses, (3) providing ancillary services to consumers or small businesses such as money orders, wire transfers and check cashing, and (4) offering other short-term consumer credit services as determined by the OCC. 

According to Mr. Mierzwinski, the bill represents an attempt by the payday lending industry to eliminate the CFPB’s supervisory authority over payday lenders that was established by the Dodd-Frank Act. Mr. Mierzwinski’s post includes a link to a June 20 letter to Congress written jointly by U.S.PIRG, the Center for Responsible Lending and the Consumer Federation of America that opposes H.R. 1909 and “and any similar legislation that may be introduced.”

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Ballard Spahr LLP | Attorney Advertising

Written by:


Ballard Spahr LLP on:

Popular Topics
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.